One minute with Claire Ayres, Head of Tax at Arrow Global.
What’s keeping you busy at work?
A huge and interesting variety of projects, from the launch and fundraising for our third credit fund and all the structuring that goes with it, lots of M&A activity, the half year rush on deal flow and financing projects, to personal tax considerations for highly mobile senior execs. The team has also doubled in size in the last 12 months, which helps manage workloads but brings its own challenges as a leader.
What do you wish you’d known at the start of my career?
How many options are available to someone with this skillset. For a long time, I considered the metric of success to be ‘Partner at a Big 4’, and indeed that is aspirational – but for me, success is not measured by job title and status, but by waking up every day and loving what I do, and having the freedom and flexibility to work in a way that allows me to enjoy other passions (such as horse riding at lunchtime).
For anyone starting out in this profession, enjoy the multinational opportunities that this type of speciality brings, travel as much as you can and keep your mind and options open to allow you to grow as a professional.
If you could make one change to tax, what would it be?
In Portugal, an annual property tax is payable based on the tax value of the property, at rates from 0.3%-0.45%. However, if the property is ‘owned’ (or ‘controlled’) by residents in blacklisted jurisdictions, this rate is increased to a whopping 7.5%. Sounds reasonable? Well yes, other than ownership being considered to be any holding company in any part of the ownership chain, however remote. There is no motive exception, and no exception if the ‘bad ownership’ has no impact on the Portuguese tax position of the local company holding the property. Moreover, there is no risk of tax evasion regarding property that, by definition, is immovable. If that wasn’t punitive enough, there are 80 blacklisted territories (compared to the EU’s 11). The Portuguese tax authorities have issued little guidance, and the legislation is recent enough for there to be little precedent. This is leading to enormous tax risks being flagged on due diligence and eyewatering insurance premiums. It’s very likely these rules will end up in the CJEU as contrary to EU law. I would change the rules so that a Portuguese tax avoidance purpose was required, which in itself means that the rules are probably redundant in their entirety.
Please share a tip about managing the in-house tax function.
Don’t say no! My mantra is that we are a function that should facilitate the organisation’s commercial goals, not stop them. It is absolutely our role to suggest the optimal way to structure a transaction, either to mitigate taxes or minimise risks, but we should not be preventing the business from doing what it needs to. We can, and should, highlight options and risks, and allow people to make informed decisions.
Also, it can’t be underestimated how integral tax is to all aspects of the business. A strong in-house function needs to really understand all facets of the organisation, commercial drivers and strategic priorities. This helps the tax function work with and not against, their key stakeholders. A team that is fully entrenched in the organisation can also be in a position to add further value by having that holistic view that other functions may not have.
And finally, you might not know this about me but...
I live in Cumbria, where my partner and I own and run a youth hostel. We are on the Pennine Way and other walking and cycle routes, and we love meeting the huge variety of people that come to stay and who also share a love of the outdoors. Our new puppy is very popular with guests!
One minute with Claire Ayres, Head of Tax at Arrow Global.
What’s keeping you busy at work?
A huge and interesting variety of projects, from the launch and fundraising for our third credit fund and all the structuring that goes with it, lots of M&A activity, the half year rush on deal flow and financing projects, to personal tax considerations for highly mobile senior execs. The team has also doubled in size in the last 12 months, which helps manage workloads but brings its own challenges as a leader.
What do you wish you’d known at the start of my career?
How many options are available to someone with this skillset. For a long time, I considered the metric of success to be ‘Partner at a Big 4’, and indeed that is aspirational – but for me, success is not measured by job title and status, but by waking up every day and loving what I do, and having the freedom and flexibility to work in a way that allows me to enjoy other passions (such as horse riding at lunchtime).
For anyone starting out in this profession, enjoy the multinational opportunities that this type of speciality brings, travel as much as you can and keep your mind and options open to allow you to grow as a professional.
If you could make one change to tax, what would it be?
In Portugal, an annual property tax is payable based on the tax value of the property, at rates from 0.3%-0.45%. However, if the property is ‘owned’ (or ‘controlled’) by residents in blacklisted jurisdictions, this rate is increased to a whopping 7.5%. Sounds reasonable? Well yes, other than ownership being considered to be any holding company in any part of the ownership chain, however remote. There is no motive exception, and no exception if the ‘bad ownership’ has no impact on the Portuguese tax position of the local company holding the property. Moreover, there is no risk of tax evasion regarding property that, by definition, is immovable. If that wasn’t punitive enough, there are 80 blacklisted territories (compared to the EU’s 11). The Portuguese tax authorities have issued little guidance, and the legislation is recent enough for there to be little precedent. This is leading to enormous tax risks being flagged on due diligence and eyewatering insurance premiums. It’s very likely these rules will end up in the CJEU as contrary to EU law. I would change the rules so that a Portuguese tax avoidance purpose was required, which in itself means that the rules are probably redundant in their entirety.
Please share a tip about managing the in-house tax function.
Don’t say no! My mantra is that we are a function that should facilitate the organisation’s commercial goals, not stop them. It is absolutely our role to suggest the optimal way to structure a transaction, either to mitigate taxes or minimise risks, but we should not be preventing the business from doing what it needs to. We can, and should, highlight options and risks, and allow people to make informed decisions.
Also, it can’t be underestimated how integral tax is to all aspects of the business. A strong in-house function needs to really understand all facets of the organisation, commercial drivers and strategic priorities. This helps the tax function work with and not against, their key stakeholders. A team that is fully entrenched in the organisation can also be in a position to add further value by having that holistic view that other functions may not have.
And finally, you might not know this about me but...
I live in Cumbria, where my partner and I own and run a youth hostel. We are on the Pennine Way and other walking and cycle routes, and we love meeting the huge variety of people that come to stay and who also share a love of the outdoors. Our new puppy is very popular with guests!
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