Property Tax Manager - eFinancialCareers : Job Details

Company DescriptionApplications close on 2/5/2024 Helping over ten million people around the world manage their savings, retirement plans and life insurance requires a lot of people behind-the-scenes. It's up to us in L&G Group functions - which includes our tech and digital teams, Group Finance, HR, Risk and Corporate Comms to provide the essential support services that all areas of the business need, here in the UK and overseas. Simply put, we enable everyone at Legal & General to do what they do best. That means we're helping to improve our customers' lives, and contributing to the success of the business every day. Job DescriptionYour role at a glanceTo work within Group Tax dealing with all areas of property tax to support the Head of LGIM Tax. To act as a tax business partner to the Real Assets team. To collaborate with another Property Tax Manager and Property Tax Compliance Manager to appropriately cover business demand. What you'll be doing

• 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.

Qualifications

• Professional Accounting Qualification (e.g. ACA or ACCA) and/or Taxation qualification (e.g. CTA) with a solid level of post qualification property tax experience within a large corporate or practice
• Good understanding of UK authorised and unauthorised property funds commonly used, including limited partnerships, property unit trusts, REITs, PAIFs, ACSs.
• Working knowledge of non-UK property fund structures (e.g. JPUTs) and exposure to other illiquid asset classes (e.g. private credit, private equity, VC).
• Good understanding of tax implications, risks and efficiencies relevant to property fund set ups, including tax transparency vs opaque for direct tax and CGT, non-resident landlord requirements and withholding tax on rents, sovereign immunity, CFC and section 13 TCGA 1992 issues.
• Practical experience of real estate funds' property / SPV acquisition, holding and eventual disposal (especially income tax, corporation tax, SDLT, capital allowances, and the construction industry scheme with some knowledge of VAT).
• Good understanding of the mechanics and accounting of commercial and residential property transactions.
• Prioritisation, planning and organisation of multi task/person assignments.
• Works with and provides guidance and support to other teams.
• Works to build contacts within the organisation.
• Proactively seeks solutions to problems.
• Ability to progress idea/solution by undertaking extra tasks proactively.
• Clarifies objectives, aims, timescales and required outcomes.
• Obtains appropriate factual data to assist in decision-making.
• Ability to make judgement calls where appropriate without referral to senior manager
• Builds and develops strong relationships with staff, peers and other contacts within the business.
• Builds and develops strong relationships with HMRC and overseas fiscal authorities, tax advisors and industry groups.
• Experience of providing tax advice to fund management teams and be able to explain tax technical issues in a clear and concise way to non-tax experts.
• Prepared to listen to others and work to understand their viewpoint.
• Ability to create and deliver clear and concise written or verbal reports.
• Ability to adapt approach to suit audience.

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