Pramod Kumar Siva

I am an international tax practitioner based in Greenville, South Carolina, with over 25 years of cross-border experience spanning North America, Europe, the Middle East, and Asia. My practice focused on transfer pricing, cross-border taxation, OECD Pillar Two (GloBE) readiness, technology-enabled compliance, multinational supply-chain structuring, and negotiating agreements with tax authorities as International Tax Director for a Fortune 500 multinational to date. Now I have started tracking AI in the International Tax space. 

International Experience: 25+ Years | 4+ Regions

I have built my hands-on global tax career on comparative frameworks, applying my "3Ts" of Tax Principles, Technology, and Transformation across borders. Real-world expatriations and sector depth (manufacturing, technology, mobility) enable me to design actionable global tax strategies that deliver measurable impact.

North America: As International Tax Officer for a Fortune 500 company, I led tax-transformation initiatives that improved efficiency and delivered significant savings for newly acquired entities. I also shape international tax policy through research, submissions, and legislative advisory work.

Europe: At the Fortune 500 headquarters in France, I directed multi-country tax planning and compliance, aligning operations with OECD BEPS and DAC6, strengthening cross-border governance.

Middle East: As Head of Tax at a regional headquarters in Dubai, I navigated complex jurisdictions, advanced transfer-pricing norms, and led tax-policy and lobbying efforts to enhance compliance and stakeholder trust.

Asia: As Associate Director at Ernst & Young LLP, I advised multinational companies on inbound investments, permanent-establishment risks, and IP licensing, overseeing high-stakes APA negotiations and M&A structuring.

Thought Leadership 

My scholarly and in-house experience position me at the intersection of international tax, technology, and transformation. I have presented at OECD consultations in Paris (Pillars One and Two), serve as Regional Vice President of the International Fiscal Association (Carolinas Region), and contribute to ABA and TEI policy forums.

At the United Nations, my engagement has grown from nomination to active contribution. With Prof. William Byrnes, I co-authored stakeholder submissions on Workstreams 1-3 of the proposed UN Framework Convention on International Tax Cooperation and on the Tax Committee's 2025-2029 work programme, and my December 2025 submission examined the "Revenue Paradox" in UN Model Article 12AA. Nominated by the ICC and Texas A&M University, I serve as the Lead Drafter on the UN Subcommittee on Artificial Intelligence in Tax Administration and co-draft four sections of its forthcoming Practical Guide. I was accredited, with the Texas A&M delegation, to the Fourth Session of the Framework Convention negotiations (New York, February 2026) and am nominated for the Fifth (August 2026). Most recently, I co-authored a July 2026 comment to OECD Working Party 6 proposing Shapley-value approaches to pricing intra-group services under Chapter VII of the Transfer Pricing Guidelines.

Academic Collaborations

Cross-border collaborations span the International Fiscal Association, Texas A&M University (Law and Business Schools), Columbia University, NOVA Tax Research Lab (Portugal), the Institute for Mergers, Acquisitions and Alliances (Vienna), and the Institute of Chartered Accountants of India. Joint research focuses on AI and global tax law, OECD Pillar Two, and international tax governance.

At Texas A&M School of Law, I serve as the guest lecturer on LAW 719 (Domestic Tax Systems Risk Management), tax technology and mergers and acquisitions topics. For the Law 719 course, I built a Pillar Two (GloBE) compliance simulator that lets students work a multinational's global-minimum-tax data problem end to end, and I mentor Texas A&M graduate students.

Projects:

1. International Tax

2. Transfer Pricing

3. Tax Technology

4. Digital Transformation 

Publications:

1. Several articles on international tax policy and the digital economy

2. Research on AI in tax administration, including agentic AI and governance frameworks for IRS compliance

3. Taxing Big Tech — game-theory analysis and policy recommendations

4. The One Big Beautiful Bill — U.S. tax reform and foreign-multinational impacts

Speaking & Mentorship

• IFA Carolinas Region & TP Minds Americas 2025 – Panelist: AI in Transfer Pricing and Tax Technology

• ABA Transfer Pricing Mentor (2024 – Present) – Loretta Collins Argrett Fellow Program

• Guest Lecturer: Texas A&M Law & Business Schools; OECD consultation debriefs; UN Sub-Committee nomination

• IMAA Faculty: Cross-border M&A and Integration Seminars

Recognition & Honors

Michelin Bib Champion (2021 and 2023) • EY Excellence Award • Elsevier Certified Peer Reviewer (2024) • Invited Presenter – OECD Paris Consultation (2019) • IFA Regional Vice President (2025) • ICC & Texas A&M University Nominee to the United National Sub-Committee on Artificial Intelligence

Professional Designations 

1. Enrolled-Agent candidate (U.S. IRS)

2. Certified Public Accountant (CPA), CPA Ireland (2019) 

3. Fellow Chartered Accountant (FCA), Institute of Chartered Accountants of India (2000)

Educational Background

1. Master of Legal Studies in International Tax, Texas A&M University School of Law (2020)

2. Graduate in Business Administration and Management, Bangalore University (1999)

This cross-border academic foundation, combined with hands-on expertise, sets me apart in the global tax field.