Senior Manager/Associate Director - UK Corporate Tax - Real Estate

Location - Bangalore/Gurgaon (hybrid)

Experience- 6-12 Years

Job Description

Key Responsibilities:

1. Corporate Interest Restriction (CIR):

- Interpret and apply key CIR concepts including:

- Definition and assessment of groups

- Calculation and application of the Group Ratio Rule (GRR) and Fixed Ratio Rule (FRR)

- Application of de minimis thresholds and the debt cap

- Assessment and impact of Public Benefit Infrastructure Exemption (PBIE) elections

- Compliance and administrative requirements

2. Other Interest Restrictions:

- Analyze interest deductibility in relation to:

- Transfer pricing (TP) adjustments

- Unallowable purpose rules

- Anti-hybrid rules

- Late payment restrictions

3. Real Estate Structures & Taxation:

- Advise on tax implications of various real estate investment structures, including:

- Fund structures, partnerships, JPUTs (Jersey Property Unit Trusts), and REITs (Real Estate Investment Trusts)

- Comparison of UK vs. non-UK holding companies for UK real estate investments

- Provide structuring advice on acquisitions, disposals, and reorganizations

4. Non-Resident Capital Gains Tax (NRCGT):

- Understand and apply NRCGT principles including:

- Identification of UK property-rich companies

- Treatment of latent gains

- Scope of UK taxation for non-UK residents on share disposals

- Application and consequences of exemption and transparency elections

5. Capital Allowances & Group Taxation:

- Advise on capital allowance claims within property structures

- Apply group tax principles, including:

- Nil gain/nil loss transfers

- Degrouping charges

- Group relief claims and restrictions

- Loss relief (carry forward, carry back, and restrictions)

Advisory & Client Support:

- Provide tax structuring advice on property acquisitions and disposals

- Deliver cross-border tax advice and conduct due diligence for international transactions

- Assist clients in establishing tax-efficient property fund structures, including UK REITs

- Support clients with deferred tax accounting for complex real estate groups

- Provide specialist input on CIR, anti-hybrid, transfer pricing, and group relief interactions

- Participate in client pitches, proposal preparation, and other business development activities

Budget- 19-27 L for Sr. Manager, 27-35 L for Associate Director