Legal Counsel

About the company: A global fintech solutions provider for financial institutions. The company delivers liquidity, trading technology, payment solutions and brokerage infrastructure through a network of specialized entities.

About the role: Senior tax lawyer with 7+ years in international tax, ideally in fintech, payments, crypto, or digital assets. The group's primary internal tax authority responsible for tax risk identification, quantification, and management across intercompany structures, regulated entities, and shareholder distributions. This is a senior individual contributor role reporting directly to the CLO.

THE LOCATION IS CYPRUS. OFFICE IS MANDATORY.

Key Responsibilities:

• International Tax Strategy: Map group's tax exposure (treaty positions, PE risks, hybrid mismatches, anti-avoidance). Maintain tax risk register. Advise on BEPS Pillar Two, ATAD, DAC6, FATCA/CRS.
• Transfer Pricing: Design and maintain OECD-aligned TP framework for management fees, IP licensing, platform access, back-office services, treasury lending, brand contributions. Prepare Master File/Local Files. Manage TP audits and MAP.
• VAT/Indirect Tax: Advise on VAT/GST for financial services exemptions, e-money, crypto, B2B tech licensing. Monitor cross-border digital services (EU OSS/IOSS, UK, UAE). Manage registrations, filings, input tax recovery.
• Dividends & Shareholder Tax: Advise on WHT on dividends, treaty-rate reductions, anti-conduit rules. Optimise holding structure (Seychelles, Mauritius, Vanuatu, Bahamas). Model profit extraction strategies (management fees, royalties, loans, return of capital).
• Corporate Tax Compliance: Oversee CIT filings across jurisdictions; review returns; support audit disclosures (IAS 12/IFRS); maintain effective tax rate model.

Mandatory:

• 7+ years in international tax; qualified lawyer or CTA/TEP/ADIT.
• In-house or consultancy background with multi-entity international groups (fintech, payments, digital assets, crypto).
• Deep knowledge of OECD TP Guidelines, BEPS Actions 4/6/7/13, Pillar Two.
• Strong DTT interpretation (UAE, Cyprus, Mauritius, Seychelles, UK treaty networks).
• Hands-on VAT experience in UAE, EU, or UK (financial services exemptions, cross-border digital services).
• Proven ability to manage external tax advisers across multiple jurisdictions.
• Self-directed, capable of operating as sole senior tax resource in lean in-house environment.
• English strong C1, exceptional written English.

Preferred:

• Prior in-house as primary tax resource at regulated financial institution, EMI, or digital asset business.
• Exposure to VARA, DFSA, CySEC, FSC, or FCA regulated environments.
• Crypto tax classification (tokens, DeFi yield, staking, NFTs).
• Economic substance requirements and FATCA/CRS reporting.

Industry Background (Non-Negotiable): High-risk industries (fintech, crypto, payments. Practical experience with high-risk business models and regulatory environments.