Tax – Dispute Resolution – Senior Consultant
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About the Division
The Taxation Services practice of Deloitte in Southern Africa has a team of legal and financial tax experts throughout the region dedicated to providing professional and robust tax advice on all local and international tax matters.
The Southern African tax environment is complex and dynamic, which makes accurate and reliable professional advice on tax matters imperative. Our clients can rely on us to meet this need, and do so in a proactive manner. We provide expert advice to clients seeking to do business on the African continent.
About the Job
We are looking for the person who is best able to fulfill the following job requirements
- Confidently provide advice to clients and Deloitte colleagues concerning procedural and practical components of the full tax dispute resolution process as contained in the Tax Administration Act, related regulations and, to a lesser extent, the Customs & Excise Act
- Provide advice to clients and Deloitte colleagues on all other aspects of the Tax Administration Act
- Formulate substantive arguments concerning appropriate penalty categories and remittance of penalties in terms of the Tax Administration Act and the Customs & Excise Act
- Drafting and submission of request for reasons letters
- Drafting and submission of applications for suspension of the obligation to pay taxes pending the resolution of the tax dispute
- Formulate substantive arguments against imposition of the capital amounts of taxation, wherever possible (and across all tax types)
- Preparation and submission of notice of objection and notice of appeal forms, including supporting letters
- Perform scenario planning and risk analysis as part of the decision-making process concerning potential settlement of tax matters
- Assistance and support during tax related negotiations
- Drafting of various tax related agreements such as extension of prescription agreements, settlement agreements and voluntary disclosure agreements (or providing commentary and tracked changes to such agreements prepared by SARS)
- Practical day-to-day handling of issues with SARS, including travelling to SARS to independently resolve certain matters, for example: delays or difficulties in obtaining tax clearance certificates or tax registrations; SARS unexpectedly taking money from clients’ bank accounts; delays in SARS refunding overpaid taxes; shipments being stopped at the border for tax related reasons; reconciliation of tax accounts and understanding the various entries and journals in the tax accounts
- Preparing briefs for counsel (to be sent through an independent attorney to counsel, in most instances)
- Project management of tax disputes, to ensure that all deadlines are met
- Maintaining client contact and building client relationships, including taking instructions from clients and updating clients on the progress on the matter
- Maintaining SARS contact and building SARS relationships
- Issue of letters of opinion regarding the prospects of success in a matter
- Issue of letters of opinion concerning the risks of a proposed transaction, including technical tax risks, practical risks, and evidentiary or other dispute related risks
- Support to counsel during the litigation process, including handling the discovery process, witness preparation and taking witness statements, and preparing documents for court
- We are looking for someone who has the following qualifications
- Admitted Attorney
- HDip (Tax), Honours in Tax or MCom (Tax) – completed or in progress
- Strong academic record
- Successful completion of studies towards an approved financial qualifications such as CFA will be a condition of employment
You would need to have the following Experience and Technical Competencies
- Very strong financial skills
- Two to five years’ relevant Tax experience, ideally involving Tax Dispute Resolution
- Computer literate
You would need to have the following Behavioural Competencies
- Creative problem solver
- Committed to personal development
- Comfortable with conflict
- Strong analytical skills
- High attention to detail
- Strong written and verbal communication / interpersonal skills
- Excellent at formulating persuasive legal and commercial arguments
- Strong relationship building skills
- Ability to work in a team
- Open and honest with high standards of ethics
- Confidence to sell services to existing and new clients
Requisition code: ZA111069LH
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One of the largest professional services organizations in the U.S., Deloitte delivers innovative solutions to the complex business problems facing companies around the world. Deloitte offers rewarding careers in four businesses—audit, tax, consulting, and financial advisory. Widely recognized for its inclusion initiatives, Deloitte is committed to building a workplace environment that allows people from all generations, ethnicities, and cultures to be their authentic selves.
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