Global ownership structuring consultant

Ownership Structuring & Advisory

• Review clients’ existing asset ownership structures, identify potential risks, and recommend appropriate solutions, including holding companies, trusts, and private foundations.

• Lead the technical aspects of client needs assessments and explain complex legal and tax concepts in clear, accessible language to business owners without specialized legal or tax backgrounds.

• Serve as the technical liaison with international lawyers, trust companies, and tax advisors in Singapore, Abu Dhabi Global Market (ADGM), and other relevant jurisdictions. The role does not involve directly practicing foreign law.

Cross-Border Tax & Regulatory Analysis

• Monitor and analyze cross-border regulatory matters, including the Common Reporting Standard (CRS), double taxation agreements (DTAs), and foreign exchange regulations governing capital transfers from Vietnam to overseas jurisdictions.

• Assess tax implications arising from asset transfers into ownership structures, including personal income tax (PIT), corporate income tax (CIT) on capital transfers, indirect transfers, foreign contractor tax, and registration fees applicable to real estate.

• Evaluate individual tax residency, worldwide income reporting obligations, and the tax treatment of distributions from trusts or foundations to beneficiaries who are Vietnamese tax residents.

• Analyze related-party transactions and transfer pricing documentation requirements under Decree No. 132/2020/ND-CP, interest expense deduction limitations, and the impact of the global minimum tax under Resolution No. 107/2023/QH15 on in-scope multinational groups.

• Apply Vietnam’s double taxation agreements and relevant international tax principles, including tax residency, Place of Effective Management (POEM), Permanent Establishment (PE), dividends, interest, royalties, capital gains, and treaty relief procedures.

• Assess anti-abuse risks, including the Principal Purpose Test (PPT) under the Multilateral Instrument (MLI), beneficial ownership requirements, and Controlled Foreign Corporation (CFC) and General Anti-Avoidance Rule (GAAR) provisions in relevant jurisdictions.

• Review economic substance requirements in jurisdictions such as the British Virgin Islands (BVI), the Cayman Islands, Singapore, and Hong Kong.

Tax Modelling & Transaction Analysis

• Develop tax models to quantify tax exposure across the asset lifecycle, including contribution, holding, distribution, transfer, exit, and succession.

• Support tax and ownership structuring analyses in mergers and acquisitions (M&A) and other complex transactions.

Knowledge Management & Professional Standards

• Maintain and update internal technical resources, including cross-jurisdictional legal comparison tables, templates, and regulatory updates.

• Conduct independent research on evolving domestic and international regulations and translate findings into practical recommendations.

• Ensure all advisory activities remain within the firm’s scope of services, focusing on asset ownership and structuring rather than the direct practice of foreign law.

Technical Knowledge & Skills

• Strong understanding of Vietnamese tax regulations and corporate finance fundamentals.

• Ability to interpret legal documents, contracts, and regulatory provisions accurately.

• Excellent English proficiency, with the ability to review legal and tax documentation, draft professional emails, and participate confidently in technical discussions with international partners.

• Strong independent research capabilities, with the ability to analyze new regulations and develop practical recommendations.

• Excellent analytical, writing, and presentation skills.

• Experience in trust structures, cross-border taxation, and regulatory procedures in Singapore or ADGM is a strong advantage.

Personal Attributes

• High integrity, discretion, and commitment to confidentiality.

• Strong analytical thinking and sound professional judgment.

• Effective communication and stakeholder management skills.

• Ability to maintain professional credibility while working closely with clients.

• Intellectual curiosity and a strong willingness to learn.

Preferred Qualifications

• A postgraduate degree in Law, an MBA, or a relevant advanced qualification.

• Evidence of strong analytical ability through academic achievements, independent research projects, moot court competitions, or similar accomplishments.

Standard benefits package, including health insurance and other employee benefits.

Opportunities for specialized training and professional development, including relevant international certifications such as those offered by STEP (Society of Trust and Estate Practitioners)

Competitive and negotiable compensation based on experience and capabilities.