Property Tax Manager

The role is broad and you will gain valuable experience in all areas of property tax. You will be involved in:

* You will provide practical tax support to the Real Assets team (fund/asset managers, transaction team, property directors and finance business partners) on ad-hoc queries and be a property tax subject matter expert to group tax colleagues. E.g. non-resident landlord, leasing and financing transactions, restructuring, property development, company liquidations, stamp duty land tax and capital allowances.
* You will provide end to end tax support and risk management, i.e. from the structuring of fund or holding entities on behalf of investor(s), to the financing and acquisition of properties or property-rich structures, to the on-going property holding or asset management (e.g. property development or conversion), to the post acquisition restructuring, and eventual exit of the underlying investments as further elaborated below. Ensure processes are followed so that the expected tax treatments identified at transaction stage are reflected in tax computations and returns.
* You will support Real Assets Product and Solutions teams on new product launches.
* You will work with internal colleagues and external advisors to structure property or property SPV acquisitions. This includes consideration of transaction tax issues (SDLT, LBTT, LTT, VAT), tax residence and PE, inherent gains, future use of property (investment vs build to rent vs develop to sell), direct tax issues, financing, transfer pricing and withholding tax.
* You will review external advisors' tax due diligence reports and manage risks within Sale and Purchase agreements' warranties/indemnities drafting and purchase price negotiations.
* You will ensure that appropriate risk management controls / procedures are in place to manage all property tax risks (including those inherited from acquired structures) on an ongoing basis. Draft and manage disclosures to HMRC when required.
* You will provide support to fund managers and client-facing colleagues with investor queries.
* You will ensure that relevant colleagues or external advisors are lined up to submit any post acquisition tax elections / returns on time. This includes VAT registration and option to tax, capital allowance election, SDLT / LBTT / LTT returns, CIS returns, etc.
* You will provide ongoing tax oversight of the range of funds and vehicles (limited partnerships, property unit trusts, joint venture companies, UK REITs and asset holding companies set up in the UK, Jersey, Luxembourg and Netherlands). This includes creating/reviewing procedure notes and ensuring compliance with direct tax, withholding tax, VAT, FATCA/CRS, construction industry scheme and ATED.
* You will prepare and collate documentation to support board decisions and tax filing positions relating to property transactions.
* You will collaborate with other members of the property tax team to share knowledge and cover busy periods or time away from the office. Support the Property Tax Compliance Manager where needed to provide information for and review annual tax compliance.
* You will keep business teams updated with key tax developments that are of relevance to them.
* You will support Group Tax's initiatives in the illiquid asset space, e.g. link in to Group Tax's response to HMRC's consultations.