Tax Manager - International Tax

Description of the role and purpose of the job

• International Tax & BEPS Pillar Two: Manager Johannesburg
• This is a role for someone who wants to help shape the next generation of international tax and Pillar Two services.
• The purpose of this role is to lead the delivery of complex international tax and BEPS Pillar Two advisory and compliance engagements for multinational clients, providing technically robust and commercially practical advice.
• The Manager will be responsible for amongst others managing client relationships, leading technical workstreams, reviewing CFC and GloBE calculations and compliance deliverables, interpreting OECD and local developments, managing teams and contributing to the growth of the firm's international tax and Pillar Two practice.
• The role requires a combination of deep technical tax expertise, commercial acumen, leadership capability and the ability to leverage technology and data to deliver innovative tax solutions.

Key responsibilities

• Lead complex international tax advisory and structuring engagements.
• Advise multinational clients on cross-border transactions and reorganisations.
• Lead treaty interpretation and withholding tax analyses.
• Advise on permanent establishment, tax residency and cross-border tax risks.
• Analyse international tax and Pillar Two implications of acquisitions, disposals and restructurings.
• Lead Pillar Two impact assessments, implementation and compliance engagements.
• Lead and review GloBE calculations.
• Advise clients on complex GloBE technical matters.
• Interpret and apply OECD Model Rules, Commentary and Administrative Guidance.
• Assess the interaction between OECD and local Pillar Two legislation.
• Lead GloBE Information Return and Pillar Two compliance engagements.
• Consider interactions between international tax, transfer pricing and Pillar Two.
• Develop technical positions and client recommendations on emerging international tax and Pillar Two matters.
• Monitor international tax and Pillar Two developments across South Africa, Africa and global jurisdictions and proactively identify implications for clients.
• Active involvement in training a diverse multicultural team.
• Prepare responses to and liaison with the South African Revenue Service and Authorised Dealers of the South African Reserve Bank.
• Lead and manage engagement teams.
• Superv the work scheduling and flows of team members.
• Coach, mentor and develop junior colleagues.
• Review technical work and provide meaningful feedback.
• Build technical capability within the international tax and Pillar Two team.
• Meeting financial targets regarding fees under management, productivity, lock-up and billings.
• Keeping up to date with changes to international tax principles, OECD Model Rules, Commentary and Administrative Guidance and legislation relating to the Income Tax Act, Global Minimum Tax Act and Global Minimum Tax Administration Act.
• Foster a culture of collaboration, accountability and continuous learning.

Skills and personal attributes

• Ability to operate proactively.
• Working on/ managing multiple projects/engagements at the same time.
• Ability to delegate – same level or downwards.
• Ability to think holistically about the impact of the global tax landscape on cross-border business operations.
• High level of tax technical competence and practical application of tax principles: ideal candidate should thrive on navigating through complex tax challenges in order to identify tax efficient solutions.
• Strong attention to detail.
• Solution driven.
• Good communication and interpersonal skills.
• Good command of the English language.
• Ability to work under pressure and deadline driven.
• Team player and good people skills.
• Ability to deal effectively with colleagues at all levels.
• Must live the KPMG values.

Minimum requirements to apply for the role including qualifications and experience:

• BCom, LLB or equivalent qualification;
• Hdip Tax, Honours or MCom in Tax; Minimum of 5 years experience in a international corporate tax consulting environment
• Demonstrable experience in BEPS Pillar Two.
• Strong technical research, analytical and problem-solving skills.
• Strong project and people management capabilities
• Ability to manage client relationships