EY Senior Manager - International Tax Transaction 

United Kingdom, England, London 

46515067

Senior Manager – Pillar 2 Technical Specialist

Technical Leadership & Interpretation

• 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.

Advisory Support

• 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.

Internal Enablement

• 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.

Client-Facing Engagement

• 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.

Required Experience & Qualifications

• 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

Why EY?

• 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.