Corporate Income Tax Audit Defence Director

The mandate

This interim assignment brings executive control to a direct-tax audit portfolio whose facts, arguments and procedural dates are not yet managed through one defensible record. The Director must start within four weeks, establish which matters threaten cash, precedent or disclosure, and create a decision route that allows responses to move without sacrificing technical quality. The purpose is controlled defence and permanent-team capability, not indefinite reliance on an external leader.

The opening month will reconcile authority correspondence, information requests, assessment status, objection rights, evidence holdings, counsel instructions and accounting exposure. Each issue will be placed on a procedural and technical map. Where historic positions lack contemporaneous support, the Director must distinguish evidence that can legitimately be reconstructed from advocacy that would weaken credibility.

Temporary authority covers portfolio triage, response calendars, factual work allocation, quality review, approved counsel briefs and escalation recommendations. Settlement, litigation commencement, precedent-setting concessions and expenditure above delegated thresholds remain reserved. The role excludes indirect-tax disputes, routine return production and redesign of the legal-entity structure, even when those matters compete for the same people.

Handover will be tested rather than declared. From month six, two permanent matter owners will chair authority interactions and draft strategy papers while the interim observes their decisions. Exit requires an accepted case file for every material issue, no missed procedural rights, quantified provision interfaces, a twelve-month forward timetable and successor-led governance operating for two complete cycles.

What you will own

• Build a verified controversy register linking every issue to facts, legal basis, evidence, amount, accounting treatment, procedural stage, deadline and reserved decision owner.
• Rank matters by cash exposure, precedent value, disclosure effect and probability of procedural loss, then redirect specialist effort against that hierarchy.
• Establish a response protocol that separates factual certification, legal interpretation, negotiation posture and executive approval before submission.
• Return draft responses that make unsupported assertions, omit contradictory evidence or fail to address the authority's precise question.
• Commission tightly scoped technical or legal advice where independence or specialist interpretation is necessary, controlling assumptions and deliverable use.
• Reconcile each material case to uncertain-tax-position accounting and forecast cash timing without allowing either record to dictate the other improperly.
• Prepare permanent owners through supervised authority meetings, red-team reviews and documented assessment of their procedural and technical judgment.
• Close the term with complete case chronologies, evidence indexes, reserved decisions, next actions and a signed acceptance record from the Group Head of Tax.

Candidate qualifications

• At least 16 years in corporate direct tax, including Director-level command of complex revenue-authority audits, objections or litigation-preparation portfolios.
• A matter where you recovered control after missed, conflicting or poorly evidenced responses, with the procedural right preserved and outcome quantified.
• Demonstrable knowledge of South African corporate-income-tax procedure and the discipline to separate legal merits, factual proof, accounting exposure and negotiation choice.
• Evidence of constructing a contemporaneous fact record from dispersed sources without overstating what historic documents could establish.
• Experience directing external counsel or specialists through precise questions, factual assumptions, privilege controls, budgets and acceptance of advice.
• A case in which you recommended settlement, litigation or concession against internal preference and obtained the required reserved decision.
• Proven transfer of a live controversy portfolio to permanent leaders using observed decisions rather than document delivery alone.

Working terms and boundaries

• The ten-month, five-day-a-week engagement permits an extension only where an external procedural timetable blocks final transfer; convenience is not sufficient.
• The interim may set case process, evidence gates and recommendations but cannot settle, commence litigation or concede precedent without reserved approval.
• Indirect-tax disputes, recurring compliance, structural tax planning and permanent recruitment are excluded and will retain separate owners.
• On-site work is expected for case-room control and authority preparation, with secure remote work permitted only for agreed analytical tasks.
• Handover is accepted after two successor-led portfolio reviews, complete files, protected procedural rights and explicit ownership of every residual decision.

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 10 October 2026. Mandate reference TAX-INT-2026-JNB-06.