Senior International Tax Counsel — Crypto & FinTech

Senior International Tax Counsel — Crypto & FinTech Location: Cyprus Work format: Office-based Employment type: Full-time Seniority: Senior Individual Contributor About the role An international fintech and digital asset group is looking for an experienced Senior International Tax Counsel to take ownership of its international tax function across a complex, multi-jurisdictional corporate structure. This is a senior individual contributor role reporting directly to the Chief Legal Officer. The successful candidate will act as the group’s primary internal tax expert, advising legal, finance and business leadership on international tax exposure, transfer pricing, VAT, corporate structuring, shareholder distributions and tax compliance. The role requires strong technical tax expertise combined with commercial judgement. You should be able to identify and quantify tax risks, challenge external advisers and recommend positions that are practical, commercially sound and defensible within regulated and high-risk business environments. Key responsibilitiesInternational tax strategy and risk management Assess the group’s international tax exposure across existing and prospective jurisdictions. Identify permanent establishment, treaty residency, management and control, economic substance, hybrid mismatch and anti-avoidance risks. Develop and maintain a group-wide tax risk register, including estimated financial exposure and probability of crystallisation. Advise on the tax implications of restructurings, new jurisdiction entries, mergers, wind-downs and ownership changes. Monitor developments including BEPS, Pillar Two GloBE, ATAD I and II, DAC6, FATCA/CRS and equivalent local regulations. Present material tax risks and recommendations to the CLO, CFO and other senior stakeholders. Transfer pricing and intercompany arrangements Design and maintain a defensible transfer pricing framework for intragroup transactions. Advise on management fees, IP licensing, technology and platform access fees, administrative services, treasury lending and brand contribution arrangements. Prepare and maintain Master File, Local File and Country-by-Country Reporting documentation where applicable. Review intercompany agreements to ensure consistency between contractual terms, operational substance and transfer pricing treatment. Assess transfer pricing risks arising from technology licensing and proprietary platform-access models. Manage transfer pricing enquiries, audits and challenges in cooperation with external advisers and local tax authorities. VAT and indirect taxation Advise on VAT, GST and equivalent indirect tax obligations across regulated and non-regulated entities. Analyse the VAT treatment of financial services, digital platforms, technology licensing, market access, data feeds and crypto-related services. Assess place-of-supply rules for cross-border digital and technology services. Oversee VAT registrations, filing obligations, input tax recovery and partial exemption positions. Advise on the VAT implications of new products, business models and geographic expansion. Dividend distributions and shareholder tax planning Analyse withholding tax exposure on dividend flows through international holding structures. Assess treaty relief, anti-conduit provisions and economic substance requirements. Evaluate profit extraction strategies, including dividends, management fees, royalties, intercompany loans and return-of-capital mechanisms. Model the tax, regulatory and reputational consequences of available structuring options. Advise on shareholder loans, convertible instruments, equity-linked arrangements, exit taxes and deemed distributions. Corporate tax compliance and reporting Oversee the corporate income tax compliance calendar across multiple jurisdictions. Review tax returns and computations prepared by local teams and external advisers. Support tax-related financial reporting, including current and deferred tax, uncertain tax positions and contingent liabilities. Maintain group tax policies and jurisdiction-level effective tax rate models. Coordinate external tax advisers and ensure consistency, quality and cost-efficiency of their advice. Cross-functional support Work closely with legal, compliance, finance and business development teams. Ensure that tax positions are consistent with regulatory capital, distribution and profit-repatriation requirements. Advise on the tax structuring of partnerships, white-label arrangements, revenue-sharing agreements and investment relationships. Support tax analysis related to regulatory-driven restructurings and new product launches. Requirements Qualified lawyer, chartered tax adviser or equivalent professional qualification, such as CTA, TEP or ADIT. At least seven years of post-qualification experience in international taxation. Hands-on experience in regulated or high-risk industries. Strong practical knowledge of crypto and digital asset business models. Experience advising complex, multi-entity international groups, preferably within fintech, payments, brokerage, financial services, digital assets or technology. Deep knowledge of the OECD Transfer Pricing Guidelines, BEPS Actions 4, 6, 7 and 13, and Pillar Two GloBE rules. Strong practical experience interpreting double tax treaties. Hands-on VAT experience in at least two of the following regions: EU member states, the United Kingdom or the UAE. Experience managing external tax advisers across several jurisdictions simultaneously. Ability to work independently as the primary senior tax resource in a lean in-house environment. Excellent written and spoken English, with the ability to produce clear and actionable tax memoranda for non-tax stakeholders. Current residence in Cyprus and willingness to work from the office. Preferred experience Previous in-house experience within a regulated financial institution, payment institution, electronic money issuer, brokerage, liquidity provider or digital asset business. Exposure to CySEC, FCA, VARA, DFSA, FSC or comparable regulated environments. Experience with the tax classification of tokens, staking rewards, DeFi income, NFTs and other digital assets. Familiarity with economic substance requirements and their interaction with transfer pricing in low-tax jurisdictions. Experience with financial instruments used in brokerage or institutional liquidity businesses, including CFDs, total return swaps, convertible loans and repo arrangements. Understanding of FATCA/CRS reporting and automatic exchange of information frameworks. Why consider this opportunity This is not a general corporate or compliance legal role. It is an opportunity to become the primary internal authority on international tax matters within a global fintech and digital asset environment, influencing both strategic decisions and the practical implementation of complex cross-border structures.