International Tax Counsel

Location: Remote within Europe Engagement: Full-time, long-term Contract: B2B Service Agreement Department: Legal & Compliance Reports to: Chief Legal Officer About the Company Our client is an international fintech group providing technology and liquidity solutions to brokers, financial institutions, and digital asset businesses. The group operates through multiple regulated and non-regulated entities across several jurisdictions and manages cross-border structures, intercompany arrangements, technology licensing models, and shareholder distribution flows. About the Role Our client is looking for an experienced International Tax Counsel to join the Legal & Compliance team and support the group’s international tax matters. Reporting directly to the Chief Legal Officer, you will work closely with finance, legal, compliance, senior management, local teams, and external tax advisers across multiple jurisdictions. The role covers international tax advisory, transfer pricing, VAT, corporate tax oversight, and support with cross-border structuring. You will help identify tax risks, coordinate compliance and documentation, and provide practical recommendations to the business. This position is suitable for an experienced international tax professional who is comfortable working independently and is interested in taking broader in-house responsibility within a lean international organisation. Key Responsibilities International Tax Advisory and Risk - Assess international tax exposure across existing and prospective jurisdictions. - Identify permanent establishment, treaty residency, economic substance, hybrid mismatch, and anti-avoidance risks. - Support the maintenance of the group tax risk register and recommend mitigation actions. - Assess how management, operational substance, and regulated entity activities affect the group’s tax positions. - Advise on restructurings, new jurisdiction entries, entity mergers, wind-downs, and ownership changes. - Monitor relevant developments, including BEPS Pillar Two, ATAD I and II, DAC6, FATCA/CRS, and local anti-avoidance legislation. - Prepare clear tax recommendations and briefings for internal stakeholders. Transfer Pricing and Intercompany Arrangements - Support the development and maintenance of the group’s transfer pricing framework. - Advise on management services, technology and platform access, IP licensing, administrative services, treasury lending, and other intragroup transactions. - Review intercompany agreements and help ensure consistent pricing and service characterisation. - Support transfer pricing documentation, including Master File, Local Files, and Country-by-Country Reporting where applicable. - Coordinate jurisdiction-specific documentation and filings with external advisers. - Support responses to tax authority queries and transfer pricing audits. VAT and Indirect Tax - Advise on VAT, GST, and equivalent indirect tax obligations across regulated and non-regulated entities. - Analyse the VAT treatment of financial services, electronic money products, technology licensing, digital services, and crypto-related activities. - Apply financial services exemptions and place-of-supply rules across the EU, UK, UAE, and other relevant jurisdictions. - Advise on input VAT recovery and partial exemption matters. - Monitor VAT registration, filing, and payment obligations. - Assess the VAT implications of new products, business models, and geographic expansion. Dividends and Cross-Border Payments - Assess withholding tax exposure on dividend distributions and other cross-border payments. - Analyse access to treaty relief, beneficial ownership requirements, and economic substance considerations. - Support the review of holding structures and profit repatriation arrangements. - Evaluate cash extraction alternatives, including management fees, royalties, intercompany loans, interest, dividends, and return-of-capital mechanisms. - Advise on shareholder loans, convertible instruments, a…