Permanent Establishment Change-Monitoring Director

The mandate

The committee wants independent challenge on whether changes in people, premises, contracts and decision conduct are identified before they create or alter permanent-establishment exposure. The standing question is not the original legal conclusion. It is whether the organisation can detect factual drift, quantify its consequence and reach the proper authority before filing and transfer-pricing positions become inconsistent.

Across the eight-month term, evidence owners attend a change clinic each week, the sponsor receives a private monthly review, and the committee considers one scheduled paper per month. The adviser first tests coverage and certifications, then follows live changes before judging whether internal leaders recognise facts that demand fresh analysis.

The adviser has no line authority, personnel approval, contract power, filing role or right to direct remediation. The Director may challenge evidence, recommend a technical review, test scenarios and state that a change has not reached adequate governance. Management owns conduct and actions; tax and authorised governance own conclusions and accepted exposure.

Current adviser, counterparty, board and investment relationships relevant to reviewed jurisdictions must be disclosed. Recusal applies where prior confidential knowledge or economic interest cannot be safeguarded. Renewal needs a newly defined question and cannot become operational monitoring performed indefinitely by the adviser.

What you will own

• Test whether monitoring covers premises, home working, travel, service duration, contracting authority, dependent agents and decision location.
• Challenge factual-owner certifications for completeness, period, corroborating records and changes since the prior review.
• Shape thresholds that trigger tax review without converting every cross-border activity into a governance escalation.
• Review selected changes for fixed-place, agency, service, project and attribution implications alongside filing and pricing consistency.
• Press management to quantify cash, accounting, compliance and controversy effects when exposure is plausible but unresolved.
• Facilitate two scenario reviews involving gradual factual drift and a sudden change close to a filing date.
• Recommend a decision log recording fact, technical owner, conclusion, implementation, revisit date and accepted residual risk.
• Deliver a closing opinion on monitoring coverage, escalation behavior and unresolved permanent-establishment vulnerabilities.

Candidate qualifications

• At least 18 years in international direct tax, including Director-level permanent-establishment analysis and governance.
• A permanent-establishment conclusion you reopened because operating conduct changed after original advice.
• Deep knowledge of fixed-place, agency, service and project exposure, attribution and interaction with filings and transfer pricing.
• Evidence of creating practical triggers that identify material change without flooding tax teams with immaterial alerts.
• Experience challenging HR, legal and operational facts while leaving management and tax authority intact.
• A conflict record suitable for confidential personnel, contract and jurisdictional information.
• Availability for two days a week and all eight Dubai governance sessions.

Working terms and boundaries

• Two adviser days are reserved every week for eight months; that capacity includes the change clinic and the scheduled monthly governance review.
• The adviser has no line authority and cannot approve mobility, contracts, filings, remediation or tax-risk acceptance.
• Detailed return preparation, attribution studies, legal drafting and operational monitoring execution are outside scope.
• Conflicts are refreshed as jurisdictions and counterparties enter review, with recusal recorded by the sponsor.
• Closure comprises a monitoring-governance opinion and transfer session; renewal requires a distinct standing 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 11 October 2026. Mandate reference TAX-ADV-2026-DXB-59.