Senior Legal Counsel (Private Client Tax & Global Mobility) | Head Office

Overview

This role provides senior legal/tax advisory for high-net-worth individuals on cross-border private client tax planning and global mobility. You will coordinate local tax and immigration providers across jurisdictions, support annual planning, and help design relocation and wealth structuring strategies.

Responsibilities

Private Client Tax Advisory

• Conduct annual tax planning for each principal, covering:
  • Tax residency status
  • Income sources
  • Planned events of the year (dividends, asset sales, relocation)
• Plan how income is received (dividends, distributions from investment funds, other payments, and loans), considering residency and available special regimes.
• Analyze the tax treatment of personal transactions, including real estate, vehicles, art, and business stakes—covering acquisition, holding, disposal, and holding-structure selection.
• Obtain and maintain special regimes for new residents and non-doms, and monitor conditions required to keep eligibility.

Global Mobility / Pre-Immigration Tax Planning

• Plan pre-immigration and exit processes, including:
  • Date of change of residence
  • Day counts and split-year treatment
  • Exit tax considerations
  • Treaty tie-breakers
  • Synchronization with immigration steps
• Design relocation routes for a principal or family together with immigration providers, including:
  • Permit/programme type (employment, business, investment, financial self-sufficiency)
  • Sequence of steps, timing, and integration requirements
• Plan transitions from temporary statuses to permanent residence and citizenship, including investment programmes, descent, and naturalisation, with associated tax consequences and risks of losing status.
• Manage family members’ matters, including reunification, parents’ residency, and children’s statuses.
• Maintain an immigration events calendar (renewals, absence limits, registrations) and control execution by immigration providers.

Wealth Structuring

• Assess the tax treatment of personal holding and investment structures (companies, funds, foundations, trusts) and recommend changes where a structure creates risk.
• Evaluate CFC, GAAR, and other anti-avoidance rules applicable to individuals.
• Plan the orderly wind-down and safe liquidation of inactive foreign companies without triggering tax.
• Advise on tax aspects of succession planning and philanthropic structures.

Advisor Management

• Select local tax and immigration advisors, brief them on a need-to-know basis, and control scope, deadlines, and fees.
• Maintain consistency of tax and legal positions across jurisdictions.

Requirements

• Ability to determine tax residency and plan a change of residence using:
  • Day-count and centre-of-vital-interests tests
  • Split-year rules
  • Exit-tax provisions
  • Treaty tie-breakers
  • Establishing the safe date and sequence of a move
• Ability to structure how an individual receives income across jurisdictions (dividends, capital gains, fund distributions, and related-party loans) and calculate after-tax outcomes of options.
• Experience obtaining and maintaining special regimes for new residents and non-doms, including eligibility assessment, elections, and ongoing monitoring (examples mentioned: Cyprus non-dom, Malta, Polish lump-sum, UK FIG, or equivalents).
• Ability to assess and manage CFC, GAAR, and anti-avoidance exposure of individuals holding foreign companies, including planning an orderly wind-down of dormant entities without triggering tax.
• Experience analyzing tax treatment of private structures (foundations, trusts, personal holding companies, and similar vehicles), including taxation of beneficiaries and distributions, and recommending changes where a structure creates risk.
• Ability to design a relocation route at global-mobility-advisor level, including selecting the permit/programme type, sequencing immigration and tax steps, identifying presence and integration requirements, and briefing/supervising immigration providers. Own filings are not required.
• Experience managing personal tax compliance across jurisdictions, including preparing or reviewing returns, CFC and foreign-asset reports, obtaining rulings, handling CRS/FATCA implications, and preparing source-of-wealth/source-of-funds narratives accepted by banks.
• Ability to provide advice that non-specialists can act on, clearly outlining options, risks, and recommendations in Ukrainian and English.
• Legal or tax qualification.

Preferred Qualifications

• Practitioner-level advisory experience in Poland or Cyprus/Malta, with working knowledge of Swiss rules and the UK FIG regime.
• Experience structuring and administering family foundations, including Polish fundacja rodzinna, and planning succession around forced-heirship rules and philanthropic vehicles.
• Experience advising on tax treatment of personal asset purchases and sales abroad (e.g., real estate, including foreign-buyer restrictions), vehicles, art, or private business stakes.
• Knowledge of residence and citizenship routes, including by investment, by descent, and naturalisation, and their tax consequences.
• Experience working with Ukrainian-origin clients and their typical holding structures.
• ADIT, CTA, doradca podatkowy, or equivalent credential.

Compensation & Benefits

• 28 business days of paid off.
• Flexible hours with the possibility to work remotely.
• Medical insurance and mental health care.
• Compensation for courses and trainings.
• English classes and speaking clubs.
• Internal library and educational events.
• Compensation/allowance for outstanding corporate parties and team-building events.

Location

• Remote work is available (location not specified).