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 focuses on transfer pricing, cross-border taxation, technology-enabled compliance, multinational supply-chain structuring, and negotiating agreements with tax authorities for a Fortune 500 multinational.

International Experience: 25+ Years | 4+ Regions

I’ve 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), represent the Carolinas Region of the International Fiscal Association, and contribute to ABA and TEI policy forums.

My work is recognized for advancing understanding of digital taxation, AI-driven tax technology, and global tax reform.

Academic Collaborations

Cross-border collaborations span the International Fiscal Association, Texas A&M University (Law & Business Schools), Columbia University, NOVA Tax Research Lab (Portugal), Institute of M&As (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.

I currently volunteer as a visiting Adjunct Faculty at Texas A&M University, as a guest lecturer on tax technology and mergers & acquisitions, and as a Regional Vice President of the International Fiscal Association (IFA - Carolinas Region).

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.