Treasury Tax - Senior Manager

The Team

KPMG’s Tax & Legal practice is a dynamic and successful part of the firm, advising a diverse client base from PE-backed, owner-managed and family businesses through to UK listed and multinational groups across a wide range of sectors.

Within this practice, the Treasury Tax team is a growing specialist group providing technical support on deals, financing transactions, international structuring and other complex tax advisory matters. We work closely with Corporate Tax client service teams to deliver high quality advice that is practical, commercially focused and technically robust.

The Treasury Tax team offers the opportunity to develop expertise in a complex and increasingly important area of tax, contributing to high-quality technical advice and helping strengthen a distinctive specialist capability within the wider Tax business.

The Role

This is an opportunity to join a growing specialist Treasury Tax team at an exciting stage in its development, working on complex financing, structuring and advisory matters across KPMG’s Corporate Tax practice.

The role offers flexibility around location and working pattern, with the individual potentially based in any of KPMG’s UK offices, albeit regular visits to London or Leeds would be preferable. Occasional travel to client or other KPMG offices may also be required.

This role will suit an experienced Manager or Senior Manager with strong technical credibility in Treasury Tax, good commercial judgement and the ability to deliver clear, practical advice on complex financing and structuring matters. A reasonable amount of direct Treasury Tax experience, or closely related experience involving loan relationships, derivative contracts and treasury activity, will be important.

As a Senior Manager in the team, you will:

• Play an important role in delivering technically excellent, commercially grounded advice on a broad range of Treasury Tax matters.
• Bring strong experience of the UK loan relationships and derivative contracts rules, ideally gained through substantial involvement in Treasury Tax advisory work, together with a sound understanding of the legal, accounting and commercial aspects of treasury activity.
• Support the continued development of the Treasury Tax capability by providing high-quality technical input on complex client matters, working closely with Corporate Tax teams and other specialists, and helping to build technical confidence and consistency across the practice.

Key Responsibilities

In this role, you will advise clients and KPMG teams on complex corporate tax matters, with a particular focus on providing technically robust Treasury Tax input and helping to deliver high-quality work across the practice. Your responsibilities will include:

• Providing robust technical advice on the UK’s loan relationships and derivative contracts regimes, including the Disregard Regulations, and related areas such as Corporate Interest Restriction, Anti-hybrids, Distributions and Withholding Tax, with appropriate review and escalation of complex technical points.
• Providing specialist input on high-profile and complex projects, including M&A and deals work, debt restructuring and refinancing, audit engagements, tax authority enquiries and complex tax compliance and advisory matters.
• Applying tax, legal, accounting and commercial knowledge of treasury matters to help clients and KPMG teams navigate complex financing arrangements and develop practical, robust and commercially relevant solutions.
• Developing strong working relationships with clients, Corporate Tax teams and other specialists across the UK, acting as a technically credible adviser on challenging Treasury Tax matters.

• Supporting the identification of client issues and opportunities for Treasury Tax input, including helping Partners and Directors shape practical responses to client needs and technical questions.
• Contributing to the technical development of the Treasury Tax team by sharing knowledge, preparing technical materials and supporting training for colleagues across the practice.
• Managing workstreams effectively, coordinating input from relevant specialists and ensuring advice is delivered to a high technical standard and in a clear, practical and commercial way.

Qualifications, Experience and Skills

• ACA, CA, CTA, ACCA or equivalent qualified, with significant corporate tax experience and ideally a reasonable amount of direct Treasury Tax experience. Strong technical expertise in the UK’s loan relationships and derivative contracts regimes, including the Disregard Regulations, and related areas such as Corporate Interest Restriction, Anti-hybrids, Distributions and Withholding Tax is expected.

• Excellent technical judgement, with the confidence to analyse complex legislation, case law and guidance, evaluate risk and provide clear, practical advice.

• Ability to work effectively with clients, client service teams and other internal stakeholders alike.

• Strong project delivery skills, with the ability to manage complex workstreams, balance competing priorities and maintain technical quality in a commercial environment.

• A collaborative approach, with a willingness to support colleagues, share technical knowledge and contribute to the development of the wider Treasury Tax capability.

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