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Corporate Tax Director

DAMAC Properties
Dubai, UAE
fulltime
Director
3 days ago
CorporateDirectorTax
Free

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CorporateDirectorTax
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Key Responsibilities

  • 1.
  • UAE Corporate Income Tax — Real Estate Compliance
  • Own the UAE CT compliance cycle for all Real Estate entities, including preparation oversight, review, and sign-off
  • Manage the calculation and filing of UAE CT returns for Properties entities, ensuring accuracy of:
  • Revenue recognition positions for off-plan and completed unit sales
  • Cost of sales treatment for development expenditure
  • Capital gain vs. income characterisation on property disposals
  • Interest deductibility — general interest limitation rule and specific real estate financing structures
  • Deferred revenue and contract liability CT treatment under IFRS 15 / UAE CT interaction
  • Related-party transaction adjustments and transfer pricing add-backs
  • Manage estimated tax payment calculations and filing calendar for all Properties entities
  • Coordinate with the India SSC CIT Compliance Manager on tax provision workings, deferred tax schedules, and compliance data preparation
  • Liaise with external UAE CT advisers on complex filing positions, seeking opinions where necessary

2. UAE Corporate Tax — Technical Advisory

  • Advise the Real Estate business line and senior management on the UAE CT treatment of key commercial transactions, including:
  • Land acquisitions — freehold vs. leasehold characterisation and CT implications
  • Development joint ventures — profit-sharing structures and CT allocation
  • Hotel and hospitality assets — mixed-use CT treatment
  • Project-level SPV structures — entity consolidation, grouping elections, and small business relief eligibility
  • Off-plan sales, escrow structures, and good registration timing
  • Property disposal structures — direct vs. share sale tax efficiency
  • Advise on the application of the UAE CT small business relief provisions and qualifying group relief to the Properties business structure
  • Assess and advise on the tax treatment of development cost overruns, contract variations, and project write-downs
  • Provide UAE CT input on new project launches, new market entries, and acquisition structures

3. Deferred Tax & Financial Reporting

  • Lead the preparation and review of deferred tax balances for all Properties entities under IAS 12 / IFRS
  • Advise on the identification of temporary differences arising from:
  • Development property held as inventory vs. investment property
  • IFRS 15 contract assets and liabilities on off-plan sales
  • IFRS 16 right-of-use assets and lease liabilities
  • Fair value movements on investment property (IAS 40)
  • Intercompany eliminations on consolidation
  • Ensure current and deferred tax disclosures in the financial statements of Properties entities are accurate, complete, and consistent with the group's tax positions
  • Brief external auditors on UAE CT positions and deferred tax judgements

4. UAE CT Structuring & Incentives

  • Identify and evaluate UAE CT incentive positions available to the Real Estate business, including:
  • Free zone qualification and the 0% Qualifying Free Zone Person regime — assessment of qualifying income vs. non-qualifying income for Properties entities in DIFC, DMCC, and other UAE free zones
  • Qualifying Group Relief elections — identifying Properties entities eligible for intra-group loss relief and transfer of assets without gain recognition
  • Tax Loss carry-forward utilisation strategy across the Properties entity portfolio
  • Advise on the CT implications of corporate restructurings within the Properties business, including entity mergers, demergers, and liquidations
  • Assess the impact of proposed group restructurings on existing CT positions, loss carry-forwards, and exemption elections
  • Monitor UAE CT legislative developments and FTA guidance and assess their impact on the Real Estate business proactively
  • 5.
  • International CT — UK, KSA, Qatar & Africa
  • Own the corporate tax compliance and advisory position for the Properties business across all non-UAE jurisdictions, including:
  • United Kingdom: corporation tax compliance for UK Properties entities; non-resident landlord regime; UK CT treatment of property disposals; Annual Tax on Enveloped Dwellings (ATED) where applicable; interaction with HMRC on property-related CT matters
  • Kingdom of Saudi Arabia: Zakat and income tax obligations for Properties entities operating in KSA; real estate transaction tax (RETT) interaction with income tax; coordination with local Saudi tax advisers on Zakat base calculations and filing
  • Qatar: income tax compliance for Properties entities operating in Qatar; QFC and onshore entity treatment; coordination with local Qatari advisers
  • Africa: oversight of corporate tax compliance across African markets in which the Properties business operates; management of local adviser network; country-by-country risk assessment and escalation
  • Manage the network of local external tax advisers across international Properties jurisdictions — setting scope, reviewing advice, and ensuring cost-efficiency
  • Ensure intercompany transactions between UAE and international Properties entities are correctly reflected in both the UAE CT computation and the relevant foreign jurisdiction CT returns
  • Advise on the CT implications of entering new international markets for the Properties business, including permanent establishment risk assessment
  • Monitor material legislative changes in KSA, Qatar, UK, and key African markets and brief the Senior Director — Direct Tax on impact
  • 6.
  • Related Party Transactions & Transfer Pricing Interface
  • Act as the primary CT interface with the SM — Transfer Pricing (Properties) — ensuring that TP arm's length adjustments are correctly reflected in the UAE CT computation
  • Advise on the UAE CT treatment of related-party transactions that have been adjusted for TP purposes, including the secondary adjustment provisions under the UAE CT Law
  • Ensure that intercompany service fees, management charges, and financing costs charged to Properties entities are correctly deducted for UAE CT purposes and are supported by appropriate TP documentation
  • Maintain awareness of UAE related-party definitions under Federal Decree-Law No. 47 of 2022, including kinship-based connected person rules, to ensure correct disclosure of all related-party dealings in UAE CT returns
  • Review UAE CT related-party disclosure requirements and coordinate with SM — TP (Properties) on consistency between the CT return and TP Disclosure Form

7. VAT & Indirect Tax Interface

  • Ensure effective coordination with the Indirect Tax pillar on VAT matters that interact with the CT position, including:
  • Input tax recovery limitations on mixed-use developments (taxable and exempt supplies)
  • VAT on commercial property leases and the landlord option to tax
  • Bare land vs. developed land VAT treatment and its CT implications
  • VAT grouping and its interaction with CT group relief
  • Flag to the Senior Director — Direct Tax any areas where the Properties VAT and CT positions are inconsistent or where an FTA challenge in one area creates risk in the other

8. Audit Defence & Tax Authority Relations

  • Lead the management of any UAE FTA corporate tax audit or enquiry relating to the Properties business line
  • Prepare technical responses, position papers, and supporting documentation for FTA queries
  • Manage the group's relationships with the UAE FTA in respect of Properties CT matters, including attendance at FTA meetings
  • Advise on and manage any voluntary disclosure requirements arising from CT position changes or errors
  • Monitor FTA audit focus areas and ensure the Properties CT position is audit-ready at all times

9. Business Partnering & Stakeholder Management

  • Act as the trusted tax adviser to the Real Estate business line leadership — embedded in key commercial decisions, not reactive to them
  • Brief the Senior Director — Direct Tax and Group Head of Tax on material UAE CT developments, risks, and opportunities for the Properties business
  • Support the Real Estate finance team with CT-related aspects of management reporting, budget modelling, and project feasibility analysis
  • Manage and develop the India SSC CIT Compliance Manager as it relates to Properties CT workstreams
  • Manage external UAE tax adviser relationships for Properties CT matters — briefing, reviewing outputs, and challenging positions

Essential

  • Professional qualification: ACA, CTA, ADIT, CPA, or equivalent
  • Minimum 15 years of corporate tax experience, with a substantial portion focused on UAE corporate income tax
  • Deep, current working knowledge of the UAE Corporate Tax Law (Federal Decree-Law No. 47 of 2022) and associated Ministerial Decisions and FTA guidance
  • Direct experience with UAE CT compliance for real estate, property development, or construction businesses — including the specific CT treatment of off-plan sales, development cost accounting, and property disposal structures
  • Strong understanding of deferred tax under IAS 12 in a real estate context — including temporary differences arising from IFRS 15, IAS 40, and IFRS 16
  • Experience with UAE CT free zone provisions — Qualifying Free Zone Person analysis, qualifying income tests, and non-qualifying income ring-fencing
  • Familiarity with UAE related-party definitions under the CT Law, including connected persons and kinship-based relationships
  • Working knowledge of UK corporation tax as it applies to real estate and property businesses, including the non-resident landlord regime and UK CT treatment of non-resident property developers
  • Working knowledge of KSA Zakat and income tax obligations for real estate businesses, including real estate transaction tax (RETT)
  • Awareness of Qatar income tax framework and CT obligations for Properties businesses operating in Qatar
  • Ability to manage and oversee CT compliance across African markets through local adviser networks, with the judgement to identify when to escalate
  • Experience managing external Big 4 or specialist tax advisers across multiple jurisdictions simultaneously
  • Track record of advising business stakeholders on CT implications of commercial transactions in a clear, practical manner

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