Legal Counsel

1. International Tax Strategy & Exposure Analysis

• Evaluate and continuously map the group's end-to-end international tax exposure across all active and prospective jurisdictions, identifying treaty positions, permanent establishment risks, hybrid instrument mismatches, and anti-avoidance vulnerabilities.
• Develop and maintain a group-wide tax risk register, quantifying the financial exposure and probability of crystallisation for each identified risk, and presenting findings to the CLO and CFO on a periodic basis.
• Assess the tax consequences of the group's legal and operational structure — including the location of key management and control functions, the substance of each regulated entity, and the group's treaty residency positions — and recommend adjustments where risk exceeds tolerance.
• Monitor and interpret legislative developments across all group jurisdictions — including BEPS Pillar Two (GloBE rules), ATAD I and II, DAC6, FATCA/CRS, and equivalent local anti-avoidance measures — and brief the group on implementation timelines and material impact.
• Advise on the tax implications of group restructurings, new jurisdiction entries, entity mergers and wind-downs, and changes to intercompany ownership arrangements.

1. Intercompany Service Agreements & Transfer Pricing

• Design, implement, and maintain a defensible transfer pricing framework for all intragroup transactions — including management fees, IP licensing arrangements, technology and platform access fees, back-office and administrative service charges, treasury lending, and brand contribution agreements — ensuring consistency with the group's overall operating model and value chain.
• Prepare and own group-level transfer pricing documentation in line with the OECD Guidelines (Master File, Local Files, Country-by-Country Report where applicable), coordinating with local external advisers for jurisdiction-specific filings.
• Review and advise on all intercompany agreements prior to execution, ensuring that pricing, payment terms, characterisation of services, and governing law are correctly reflected and consistently applied across the group.
• Identify and assess the transfer pricing risk arising from the group's technology licensing model — in particular, the characterisation of payments for access to any proprietary platforms by regulated operating entities — and establish defensible benchmarks.
• Respond to transfer pricing queries, information requests, and audit challenges from local tax authorities; coordinate and supervise external advisers on transfer pricing defence; manage settlement negotiations under competent authority and mutual agreement procedures (MAP).
• Assess the impact of new OECD and local TP developments — including Amount B under Pillar One and digital services provisions — on the group's existing intercompany structures.

1. VAT & Indirect Tax

• Advise on VAT, GST, and equivalent indirect tax obligations for each regulated and non-regulated group entity, with particular attention to the VAT treatment of financial services (including the scope of financial services exemptions under UAE VAT, EU VAT, and UK VAT), electronic money products, B2B technology licensing, and crypto-related services.
• Analyse the place-of-supply rules applicable to the group's cross-border digital service flows — including the supply of technology platforms, data feeds, market access services, and trading infrastructure — and establish compliant VAT treatment for each category.
• Monitor VAT registration thresholds and obligations arising from the group's activity in the EU (OSS/IOSS mechanics for digital services), UK, UAE, and other relevant jurisdictions; maintain a VAT registration calendar and ensure timely registration, filing, and payment.
• Manage input tax recovery and partial exemption positions for holding entities, intermediate companies, and mixed-use operating entities, including annual adjustments and capital goods scheme calculations where applicable.
• Advise on the VAT implications of new product launches, new business models, and geographic expansion before commitments are made.

1. Dividend Distributions, Free Cash Flow & Shareholder Tax Planning

• Advise on the withholding tax implications of dividend flows from operating entities through intermediate holding structures to ultimate beneficial owners, including the availability and conditions for treaty-rate reductions and the impact of anti-conduit provisions.
• Review and optimise the group's holding structure to minimise tax friction on upstream profit repatriation, having regard to treaty residence requirements, economic substance obligations (particularly in Seychelles, Mauritius, Vanuatu, and the Bahamas), and the interaction with BEPS minimum standards.
• Evaluate free cash flow extraction strategies — including management fee arrangements, royalty flows, intercompany loans and interest, and return-of-capital mechanisms — for tax efficiency, regulatory compatibility, and defensibility; model the after-tax cost of each strategy for management.
• Brief the CLO/CFO and, where appropriate, the Board on available profit extraction and capital optimisation scenarios, including the tax cost of each option and the reputational and regulatory risks associated with aggressive positions.
• Advise on the tax treatment of shareholder loans, convertible instruments, and equity-linked arrangements at the level of the regulated holding entities.
• Assess exit tax and deemed distribution consequences arising from changes to the group's holding structure or the migration of entities between jurisdictions.

1. Corporate Tax Compliance Oversight

• Oversee the group's corporate income tax compliance calendar across all active jurisdictions, coordinating with external tax advisers and local finance teams to ensure accurate, timely filing and payment.
• Review corporate income tax returns and computations for material entities; challenge positions taken by external advisers where appropriate; escalate material discrepancies or risks.
• Support the group audit process on all tax-related financial statement disclosures, including current and deferred tax provisions, uncertain tax positions (IAS 12 / IFRS), and contingent tax liabilities.
• Maintain a group tax policy document and a jurisdiction-by-jurisdiction effective tax rate model; report quarterly on variances from plan.

1. Regulatory & Cross-Function Coordination

• Liaise with local compliance teams, legal counsel, and external tax advisers to ensure that tax positions are consistent with each entity's regulatory capital, distribution, and profit-repatriation obligations under applicable licence conditions.
• Advise the CLO on the tax implications of new regulatory requirements — for example, changes to prudential capital treatment, new AML/CFT reporting obligations with tax disclosure consequences, or regulatory-driven entity restructurings.
• Support corporate finance and business development teams on the tax structuring of new partnerships, white-label arrangements, revenue-sharing agreements, and investment relationships.

Obligatory

• Experience in high-risk industries is mandatory.
• Strong knowledge of crypto is required.
• Experience only in banks or major law firms is not sufficient for this role.
• The person must have practical experience with high-risk business models and regulatory environments.
• Qualified lawyer or chartered tax adviser (CTA, TEP, ADIT, or equivalent) with at least seven years of post-qualification experience in international tax.
• Demonstrable experience advising multi-entity international groups — ideally in financial services, fintech, payments, digital assets, or technology-enabled businesses with complex cross-border structures.
• Deep working knowledge of the OECD Transfer Pricing Guidelines, BEPS Action Plans (in particular Actions 4, 6, 7, and 13), and Pillar Two GloBE rules.
• Strong command of double tax treaty interpretation; practical experience with the UAE, Cyprus, Mauritius, Seychelles, and/or UK treaty networks is a significant advantage.
• Hands-on experience with VAT in at least two of: UAE, EU member states, or UK — including financial services exemption analysis and cross-border digital supply chain classification.
• Proven ability to manage external tax advisers across multiple jurisdictions simultaneously, ensuring quality, cost-efficiency, and consistency of advice.
• Comfortable operating as a sole senior tax resource in a lean in-house environment — self-directed, highly organised, and capable of managing multiple workstreams without requiring large team support.
• Exceptional written English; ability to produce clear, structured, and actionable tax memoranda and briefing papers for non-tax audiences.

Preferably

Prior in-house experience at a regulated financial institution, payment institution, electronic money issuer, or digital asset business, where the candidate was the primary tax resource rather than one of many.
Exposure to VARA, DFSA, CySEC, FSC, or FCA regulated environments from a tax structuring or compliance perspective.
Experience with crypto and digital asset tax classification questions — including the characterisation of tokens (utility, security, payment), DeFi yield, staking rewards, and NFTs — for both entity-level tax reporting and structuring purposes.
Familiarity with economic substance requirements and their interaction with transfer pricing in low-tax jurisdictions.
Experience advising on the tax treatment of financial instruments used in prime brokerage or institutional liquidity contexts, including CFDs, total return swaps, convertible loans, and repo arrangements.
Exposure to FATCA/CRS reporting obligations for financial institutions and the interaction between automatic exchange of information frameworks and group tax positions.

• Reliability: official employment from the first day, bonuses, annual employee review (salary review or bonus, feedback on work results)
• Stability: our clients are in different countries, therefore we are ready for any changes in work of any country
• Development: a lot of projects and products, which means increasing expertise in working with different technologies, or even switching to completely new ones for you within the company
• Active corporate life: we participate in thematic conferences and forums in our cool sphere of business, corporate parties in the best restaurants of the city with participation of stars, etc
• Comfort: Offices are in different countries. You can work from anywhere in the world