Tax Technical Adviser

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Business Assets International (BAI) sits within the Strategy and Policy Directorate which is responsible for leading on strategy, policy, guidance, analytical, customer, business architecture and design functions.

You can learn more about the Strategy & Policy Directorate on its dedicated careers website; HMRC ? Customer Strategy & Tax Design , Civil Service Careers

BAI is HMRC?s centre of expertise for business, asset and international taxation, shaping and delivering policy that supports economic growth and ensures a fair and effective tax system. We work closely with compliance and operational teams to tackle avoidance and risk, providing high-quality technical advice and supporting litigation to ensure consistent and robust outcomes.

We are recruiting a Grade 7 tax technical adviser to join the Trading, Property and Miscellaneous Income Team within the Business Profits Team (BPT). BPT designs and maintains the rules governing trading income, property income and miscellaneous income and provides authoritative technical and policy advice on some of the most fundamental questions in direct tax.

This is a high-profile senior specialist role. It offers the opportunity to lead complex, challenging and rewarding technical work affecting businesses of all sizes, including disputes involving avoidance, litigation, governance decisions and issues of wider policy significance. The role is not simply about answering technical queries: you will be expected to exercise professional judgement, provide leadership through expertise, and influence robust and consistent outcomes across HMRC.

You will advise and support operational colleagues as they consider fundamental but often difficult questions about the correct application of the tax rules. Are costs capital or revenue? Was expenditure incurred wholly and exclusively for business purposes? Are the activities more hobby than business? You will need to apply legislation, case law, guidance and policy intent to new or uncertain scenarios, defend HMRC?s technical position and explain your conclusions clearly to both technical and non-technical audiences.

There is an expectation that successful applicants will be able to apply their skills flexibly across all BPT areas of work, including where issues cut across different business profits regimes or interact with wider HMRC priorities.

Duties of this role include:

• Developing deep technical knowledge of relevant legislation, guidance and case law, and applying that knowledge confidently to novel, complex or untested scenarios.
• Providing authoritative technical advice and leadership to colleagues across HMRC on tax disputes, including avoidance cases and matters progressing through formal governance or litigation.
• Working closely with legal colleagues and Counsel to develop and articulate HMRC?s technical position, prepare arguments and support cases before Tax Tribunals and higher courts.
• Establishing and developing effective relationships with stakeholders across HMRC, HM Treasury, Other Government Departments and Devolved Administrations, including contributing to policy development and fiscal event work where BPT issues are relevant.
• Engaging with operational, policy and technical colleagues to ensure legislation works as intended, guidance is clear, and HMRC staff and customers have a consistent understanding of the rules.
• Providing technical advice on issues of topical, political or ministerial interest, including Parliamentary Questions, Ministerial Correspondence, Freedom of Information requests, submissions and briefing for senior stakeholders.
• Contributing to the development of the team and BAI more widely by sharing knowledge, supporting capability building, identifying common issues and helping to promote consistent technical standards.

The role involves meetings with Counsel and attendance at Tribunals and Courts. Although many meetings are now conducted via Teams, attendance in London, sometimes at short notice, may be necessary. You may be required to attend Tribunal hearings for several consecutive days, either in person, via the Tribunal?s own hearing platform or Teams depending on business needs. While reasonable regard will be taken of working patterns, some short notice travel may be required.

• Demonstrate strong direct tax technical expertise and analytical ability, drawing on legislation, case law, guidance and policy material to provide robust advice on complex or contested issues across income tax and corporation tax, while rapidly developing expertise in new areas as required.
• Work collaboratively and proactively to take ownership of complex technical issues, managing competing priorities and ambiguity at pace while drawing on expertise from across HMRC to deliver robust outcomes.
• Demonstrate the ability to build effective relationships and influence decisions across diverse stakeholder groups, using insight from common issues, trends and emerging themes to drive consistent technical outcomes, improve guidance and support effective policy development.
• Provide clear, authoritative and proportionate advice on complex tax technical issues, tailoring communications to diverse audiences and influencing decision-making through effective engagement with senior colleagues, governance boards, legal advisers and appointed Counsel.
• Demonstrate professional leadership through expertise, including supporting the development of colleagues and contributing to the wider Tax Profession.

Essential Criteria

This is a Tax Profession role. Applicants must demonstrate that they meet both the qualification requirement and the professional experience requirements for the role. You must be able to demonstrate evidence of:

• Applying direct tax legislation, case law, guidance or policy material to complex technical issues, including issues where the position is uncertain or contested.
• Providing clear, reasoned and persuasive advice or recommendations to support decisions by senior stakeholders, governance boards or equivalent decision-makers.
• Working collaboratively across organisational boundaries to resolve complex technical, policy or operational issues.
• Communicating complex technical material clearly to different audiences, including non-specialists.
• Managing a varied workload at pace while maintaining quality, judgement and attention to detail.
• Professional experience requirement.

Qualification requirement

The post holder must hold one or more of the Qualifications noted below.

Further Location Information

Please ensure that you only apply for a location that you are willing and able to work from, as we will only make one offer of employment. Any additional notes included in a ?Further Location Preferences (optional)? field within the application form, will not be considered. Please be aware that you cannot change your location preference after submitting your application.

Additional Security Information

Please note that if you are appointed to 100 Parliament Street, as a condition of working in this location you will be required to obtain Counter Terrorist Check (CTC) level clearance.

To obtain this level of clearance, you will normally need to meet the minimum UK residency period, which for CTC is 3 years UK residency prior to your vetting application.

You may not be able to start in the location until clearance is granted.

If you have any questions about this residency requirement, please speak to the vacancy holder for this post.

• HMRC's Tax Specialist Programme or predecessor qualifications (TPDP, IDP, ITS2, CPT, FT2).
  
• Chartered Tax Adviser (with direct taxes options).
  
• Advanced Diploma in International Taxation.
  
• Full membership of one of the Consultative Committee of Accountancy Bodies (ICAEW, ICAS, CAI, ACCA, CIPFA), provided that direct tax matters make up a substantial part of your professional experience.
  
• Qualification as a Solicitor, Barrister or CILEX Lawyer (including the Professional stage Business and Commercial Law module) in England and Wales (or equivalents in Scotland and Northern Ireland), provided that direct tax matters make up a substantial part of your professional experience.
  
• Equivalent qualifications or relevant experience may be considered on a case-by-case basis.

We'll assess you against these behaviours during the selection process:

• Communicating and Influencing
• Working Together
• Delivering at Pace

HMRC operates both Flexible and Hybrid Working policies, allowing you to balance your work and personal commitments. We welcome applications from those who need to work a more flexible arrangement and will agree to requests where possible, considering our operational and customer service needs.

We offer a generous leave allowance, starting at 25 days and increasing by a day for every year of qualifying service up to a maximum of 30 days.

• Pension - We make contributions to our colleagues? Alpha pension equal to at least 28.97% of their salary.
• Family friendly policies.
• Personal support.
• Coaching and development.

To find out more about HMRC benefits and find out what it?s really like to work for HMRC hear from our insiders or visit Thinking of joining the Civil Service

Job contact :

• Name : Clare Irvine
• Email : clare.irvine@hmrc.gov.uk
• Telephone : 03000586478

Recruitment team

• Email : unitybusinessservicesrecruitmentresults@hmrc.gov.uk