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Freelance Tax Consultant — Cross-Border Group Restructuring (Remote / Project-Based)
A UK-headquartered technology group operating in SaaS and bespoke software development alongside B2B hardware (TV set-top boxes and digital signage) and related software support are seeking an experienced independent tax consultant for a defined advisory project.
The group has an annual turnover of around £15-30mil, is privately owned following a recent take-private, and has around 15 legal entities across the world.
The Project:
My client needs someone urgently to come in and build a phased plan to reset and simplify a large population of intercompany balances using dividends in specie, capital contributions, write-offs of immaterial balances and a small number of new formal loan agreements. They would then need independent tax advice on the plan before they implement it.
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Scope Includes:
- Tax treatment of the proposed settlement mechanisms across eight jurisdictions
- Debt/equity conversion, arm's-length interest and transfer pricing considerations
- Withholding tax on cross-border dividends in specie and loan interest
- Deductibility of write-offs and treatment of capital contribution routes
- A template transfer pricing policy and the benchmarking scope to support it
- Restructuring relief, de-grouping and anti-avoidance risk from historic novations
- Recommended tax sequencing of the settlement steps, plus a tax review of four planned liquidations
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Ideally the client needs a written report by entity/jurisdiction, a template transfer pricing policy, and a recommended execution sequence too.
The Role:
The role will suit a freelancer or Interim with strong cross-border group tax, reorganisation, intercompany debt/equity and transfer pricing experience, ideally gained with similarly structured small multinational groups.
Legal and company law matters sit outside this scope and are handled separately with in-country counsel.
Note:
The role is deemed outside IR35, apply if you feel this could be a good fit.
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