Cross-Border Financing Tax Governance Director

The mandate

The committee wants an independent answer to a recurring question: do cross-border financing choices balance funding purpose, legal capacity, tax effect, accounting treatment and governance risk before commitments are made? Technical advice often arrives by instrument or jurisdiction, while directors must compare the full consequence and determine whether assumptions about debt capacity, treaty access or interest deductibility remain credible.

The six-month schedule includes one weekly financing clinic, a monthly sponsor review and one scheduled committee session each month. The adviser will initially test decision papers and authority routes, then observe selected financing proposals and finally assess whether the governance method can operate without recurring external intervention.

This role exercises influence only and carries no line authority, treasury mandate, transaction approval or legal-signature right. The Director may challenge assumptions, request evidence through the sponsor, propose scenarios and recommend escalation. Treasury, tax, accounting and board owners retain their respective decisions and implementation obligations.

All lender, adviser, counterparty, investment and board relationships relevant to financing choices must be disclosed. Where information barriers cannot address actual or perceived conflict, the adviser will recuse. Renewal requires a newly defined strategic question and will not arise automatically because individual financings remain in execution.

What you will own

• Test whether financing papers state funding purpose, alternatives, borrower capacity, currency, tenor, security, decision conduct and implementation dependencies.
• Challenge debt-equity, interest-limitation, withholding, treaty, transfer-pricing, hybrid and minimum-tax assumptions against coherent facts.
• Shape a comparison framework covering after-tax cash, accounting impact, legal flexibility, covenant resilience, tax uncertainty and unwind cost.
• Press decision owners to identify the condition under which a preferred structure ceases to be supportable or valuable.
• Review authority matrices so tax and treasury concurrence does not substitute for reserved approval or obscure accountable recommendation.
• Facilitate two scenario reviews involving rate movement, forecast deterioration, treaty challenge or delayed legal execution.
• Recommend monitoring triggers for changes in debt capacity, use of funds, conduct, deductibility and withholding evidence after implementation.
• Provide a closing view on governance quality, recurring evidence weaknesses and questions that require continuing committee attention.

Candidate qualifications

• At least 18 years in international tax, treasury taxation or financing governance, including Director-level advice to executive or board forums.
• A financing choice where your challenge changed instrument, amount, jurisdiction, timing or approval route, with the consequence quantified.
• Strong understanding of interest limitation, withholding, treaties, transfer pricing, debt capacity, hybrids and tax-accounting interaction.
• Evidence of comparing tax efficiency with covenant, accounting, legal and unwind consequences rather than optimising one measure.
• Experience advising without assuming treasury execution or transaction approval, leaving ownership visible in the decision record.
• A conflict history suitable for access to confidential lender, adviser and counterparty information.
• Availability for three days a week and all six scheduled Toronto governance sessions.

Working terms and boundaries

• The monthly retainer covers three days a week for six months, weekly clinics and one board or committee meeting each month.
• The adviser has no line authority and cannot select lenders, approve instruments, direct transactions, sign documents or accept tax risk.
• Drafting transaction documents, obtaining opinions and conducting execution are outside scope unless separately commissioned.
• Conflicts are refreshed before each selected financing review, with recusal and access controls documented through the sponsor.
• The appointment ends with a governance assessment and transfer workshop; renewal requires a distinct committee question.

Application

Applications for this mandate are received in one way only: through the India Board Terminal's application process. It is automated end to end. Your Executive Passport travels to the mandate holder in its confidential form, your answers to the three questions below are read before anything else in your file, and every stage that follows is recorded on your applications page.

There is no address to write to and no intermediary to call. The mandate holder reads what the Terminal delivers and nothing else, which is what keeps the process the same for every applicant and keeps your name out of it until you release it. Applications close on 7 October 2026. Mandate reference TAX-ADV-2026-TOR-27.