
Senior Manager - International Tax and Transaction Services - Pillar 2 Specialist
- London
- Permanent
- Full-time
- Interpret the OECD Model Rules, Commentary, Agreed Administrative Guidance, and local legislation to support client positions and EY technical guidance.
- Develop and maintain EY's UK position on complexities of the GloBE Model Rules, UK Multinational Top-up Tax legislation.
- Advise on the Pillar 2 impact of reorganisations, transactions and M&A.
- Advise clients on complex technical questions, including classification of Constituent Entities, PE attribution, and GloBE adjustments.
- Support global engagement teams with structuring and modelling advice, including:
- ETR forecasting
- QDMTT and top-up tax interplay
- Planning around elections and safe harbour options
- Provide insights into audit readiness, governance, and potential risk areas under the GloBE rules.
- Deliver training and guidance to GCR, ITTS, and TTT teams across the UK.
- Create and maintain technical tools including FAQs, decision trees, and implementation guides.
- Collaborate closely with EY's global Pillar 2 technical network to ensure consistency and share insights.
- Serve as a technical SME on complex advisory and compliance readiness projects.
- Translate detailed technical rules into implementable, practical steps for clients.
- Join client workshops and review sessions, particularly where advisory overlays or bespoke rulings are required.
- ACA, CTA, or equivalent professional qualification.
- Strong technical background in international tax, with experience in Pillar 2, BEPS, hybrid mismatches, or CFC rules.
- Demonstrated ability to apply tax law to real-world client situations, particularly for multinational groups.
- Excellent written and verbal communication skills; capable of articulating complex technical positions clearly and persuasively.
- Prior engagement with HMRC or other tax authorities on international tax issues is desirable.
- An existing focus and tangible experience advising on Pillar 2 is desirable
- Be part of one of the largest and most technically advanced international tax teams in the world.
- Work with industry-leading professionals shaping global tax policy and client strategy.
- Play a central role in one of EY's most high-profile campaigns, with excellent opportunities for personal progression.
- Access cutting-edge technology and work on the most challenging Pillar 2 projects in the market.