Treaty Entitlement and Permanent Establishment Governance Director

The mandate

The board needs a recurring independent view on whether treaty claims and permanent-establishment positions remain aligned with how decisions and activities actually occur. The question persists because legal form, operating conduct, personnel movement and documentary evidence evolve at different speeds. The adviser will help governance identify when an apparently settled position must be reopened before an authority does so.

The ten-month cadence includes a weekly evidence clinic, a monthly sponsor session and six scheduled committee appearances. Initial work will test the position inventory and factual ownership; later sessions will examine changes in decision location, contracting, authority, personnel activity, agent conduct and substance. Ad-hoc questions receive a response within three business days when they remain inside the agreed perimeter.

This is an influence-only appointment with no line authority, filing role, legal opinion or transaction approval. The Director may press for factual proof, test consistency, recommend an independent opinion and advise the committee that a position is not decision-ready. Management owns facts and implementation; authorised governance owns acceptance of tax risk.

Concurrent work for a counterparty, tax authority, adviser or governing body connected to a matter under review must be disclosed promptly. Recusal is mandatory where information barriers cannot preserve independence. The appointment ends after the closing opinion unless the committee defines a new question; continuing operational remediation does not itself justify renewal.

What you will own

• Review the inventory of treaty-relief and permanent-establishment positions for completeness, factual ownership, evidence currency and reconsideration triggers.
• Challenge beneficial-ownership, residence, principal-purpose, agency, fixed-place and service-duration assumptions against observable conduct rather than policy statements alone.
• Shape a factual certification protocol covering decision location, contracting authority, travel, premises, personnel activity and changes during the period.
• Test whether withholding and filing consequences reconcile with the governing treaty position and whether inconsistency is explicitly understood.
• Recommend thresholds for external opinion, voluntary correction, protective filing or board risk acceptance without directing the chosen response.
• Facilitate two red-team sessions in which management must defend selected positions against a credible authority fact pattern.
• Establish a committee view that separates technical strength, evidential strength, cash exposure, precedent risk and remediation readiness.
• Issue a final independent opinion on governance sufficiency, unresolved factual weaknesses and the decisions that remain with accountable leaders.

Candidate qualifications

• At least 18 years in international direct tax with Director-level responsibility for treaty access, permanent-establishment analysis and governance of cross-border facts.
• A matter where operating conduct invalidated or materially changed an assumed treaty or permanent-establishment position and your challenge altered the response.
• Deep command of residence, beneficial ownership, treaty anti-abuse, dependent-agent, fixed-place and service-permanent-establishment analysis.
• Evidence of creating factual certifications that remained usable across tax, legal, finance and operational ownership without becoming a legal conclusion by questionnaire.
• Board advisory experience that preserved influence-only boundaries while making an uncomfortable risk decision unavoidable.
• A conflict and confidentiality record suitable for access to privileged cross-border facts and concurrent advisory appointments.
• Availability for the weekly remote cadence and all six scheduled Zurich governance sessions.

Working terms and boundaries

• The retainer covers two days a week for ten months, weekly evidence clinics, monthly sponsor reviews and six committee meetings.
• The adviser has no line authority and cannot certify facts, issue legal opinions, approve filings, direct remediation or accept tax risk for the board.
• Extraordinary attendance, litigation support and new transaction analysis are excluded unless the sponsor approves a separately priced scope.
• Conflicts are refreshed before each selected-position review, with recusal recorded and information access restricted where necessary.
• The term concludes with a written governance opinion and transfer discussion; renewal requires a different standing question and fresh approval.

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-ZRH-11.