Associate Director - Advisory/UK Corporation Tax - ACCA - Real Estate Domain (8-15 yrs)

- For an Associate Director the expectations are higher than Manager and we would test for some or all of the below technical points. Ideally the AD would be able to cover or have awareness of to the extent these came up in complex compliance and advisory work:

Understand key concepts under the corporate interest restriction regime and apply these, including:

- Concept of a group

- GRR and FRR and how to apply these

- De Minimis

- Debt cap

- Impact of the PBIE election

- Compliance and admin requirements

In addition to CIR, understanding other ways interest can be restricted, including:

- TP

- Unallowable purpose

- anti hybrid

- late payment

Understanding different RE structures, including:

- Fund structures

- Partnerships

- JPUTs

- REITs

- UK vs non-UK companies for holding UK RE

- REITs

NRCGT principles, including:

- Concept of a UK property rich company

- Latent gains

- Scope of UK tax on gains for non-UK residents (including disposals of shares)

- Exemption and transparency elections application and consequences of making elections in relation to filings

- Capital allowance principles

Concept of groups for gains and loss purposes, including:

- Nil gain nil loss principles

- Degrouping charges

- Group relief claims

Losses more widely, carry back, carry forward provisions, restriction on carry forward

Must Haves:

- Advisory Experience in UK Corporation Tax, leadership skills, how to handle difficult situations/teams.