Property Tax Manager

2 weeks ago

London, Greater London, United Kingdom Legal & General Full time
About the Role

We are seeking a highly skilled Tax Professional to join our team as a Property Tax Manager. This is a 9-month fixed-term contract opportunity that will provide you with the chance to work on a variety of challenging projects and develop your skills in a dynamic and supportive environment.

Key Responsibilities
  • Provide tax support to our Real Assets team, including fund/asset managers, transaction teams, property directors, and finance business partners.
  • Act as a tax subject matter expert, providing guidance on non-resident landlord, leasing and financing transactions, restructuring, property development, company liquidations, stamp duty land tax, and capital allowances.
  • Support the structuring of fund or holding entities on behalf of investors, from the financing and acquisition of properties or property-rich structures to the on-going property holding or asset management.
  • Work with internal colleagues and external advisors to structure property or property SPV acquisitions, considering transaction tax issues, tax residence and PE, inherent gains, future use of property, direct tax issues, financing, transfer pricing, and withholding tax.
  • Review external advisors' tax due diligence reports and manage risks within Sale and Purchase agreements' warranties/indemnities drafting and purchase price negotiations.
  • 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.
  • Provide support to fund managers and client-facing colleagues with investor queries.
  • Ensure that relevant colleagues or external advisors are lined up to submit any post-acquisition tax elections/returns on time, including VAT registration and option to tax, capital allowance election, SDLT/LBTT/LTT returns, CIS returns, etc.
  • Provide ongoing tax oversight of the range of funds and vehicles, including limited partnerships, property unit trusts, joint venture companies, UK REITs, and asset holding companies set up in the UK, Jersey, Luxembourg, and Netherlands.
  • Prepare and collate documentation to support board decisions and tax filing positions relating to property transactions.
  • 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.
  • Keep business teams updated with key tax developments that are of relevance to them.
  • Support Group Tax's initiatives in the illiquid asset space, e.g., link in to Group Tax's response to HMRC's consultations.
Requirements
  • 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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