Senior Manager - International Tax and Transaction Services - Pillar 2 Specialist

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Job Title: Senior Manager – Pillar 2 Technical Specialist

Role Summary

EY is seeking a technically strong Senior Manager to join our growing Pillar 2 team within the International Tax and Transaction Services (ITTS) practice. This is a market-facing, technically focused role where you will be at the forefront of interpreting and applying the OECD GloBE Model Rules, the EU Minimum Tax Directive, and UK legislation to help Multinationals understand the tax impact and advisory implications of Pillar 2.

You will play a key role in supporting the execution of EY’s Pillar 2 campaign by shaping the firm’s technical views, supporting internal enablement, and providing high-value advisory input across EY’s client base. You will also support our Global Compliance & Reporting (GCR) and Tax Technology & Transformation (TTT) colleagues on the advisory aspects of Pillar 2 compliance.

Key Responsibilities

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.

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