INTERNATIONAL TAXATION CONFERENCE
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
This page contains copies of the slide presentations of conference speakers and handout materials provided by them.
An audio/video CD recording of the entire conference is sent to each delegate after the conference.
2005 CONFERENCE – DECEMBER 2-3, 2005 – MUMBAI
Conference Chairman: Klaus Vogel
Conference Director: Roy Rohatgi
Thursday, December 1, 2005 (19.00 – 22.00)
Welcome Social Evening – Cocktails and Dinner
Friday, December 2, 2005
| Day 1 | |
| 09.00 – 10.00 | Registration & Coffee |
| 10.00 – 10.15 | Welcome to the Conference Anant Singhania (President, BMA) Roy Rohatgi (Conference Director) |
| Session One | |
| TRANSFER PRICING | |
| Chairman | Sohrab Dastur, Senior Advocate, India |
| 10.15 – 11.45 | Special Speaker: Hubert Hamaekers, former Chairman of the Board of Management of the International Bureau of Fiscal Documentation, Amsterdam, The Netherlands Recent Developments in International Transfer Pricing (Presentation & Questions) Click Here to view the Presentation  |
| 11.45– 12.25 | Peter Barnes, Head of Tax, General Electric Corporation, United States Transfer Pricing Issues in a Large Multinational Company Click Here to view the Presentation |
| 12.25 – 12.45 | Discussion and Questions |
| 12.45 – 13.00 | Session Chairman’s Remarks |
| 13.00 – 14.00 | Lunch |
| Session Two | |
| TRANSFER PRICING IN PRACTICE | |
| Chairman | Jairaj Purandare, Senior Executive Director, PricewaterhouseCoopers (P) Ltd., India |
| 14.00 – 14.40 | Akhilesh Ranjan, Director (International Taxation), Government of India Transfer Pricing Rules under Indian Tax Law – A Revenue View Click Here to view the Presentation |
| 14.40 – 15.20 | Shyamal Mukherjee, Partner, PricewaterhouseCoopers (P) Ltd., India Transfer Pricing Issues in India – A Practitioner View Click Here to view the Presentation |
| 15.20 – 16.00 | Vispi T Patel, Partner, Deloitte Haskins & Sells, India Transfer Pricing Audits – Indian Experience Click Here to view the Presentation |
| 16.00 – 16.30 | Tea |
| 16.30 – 17.00 | Discussion & Questions |
| 17.00 – 17.50 | Caroline Silberztein, Organisation for Economic Co-operation & Development, Paris, France Practical Issues relating to the Choice of Comparables in Transfer Pricing/ (Presentation & Questions) Click Here to view the Presentation |
| 18.00– 19.00 | Special Session Chairman – Rashmin Sanghvi, Partner, Rashmin Sanghvi Associates, India Klaus Vogel, Professor Emeritus, University of Munich, Germany Tax Treaties – Recent Case Law around the World (Presentation and Questions) |
| 19.00 – 22.00 | Cocktails and Dinner Presentation on Singapore Tax and Trusts by The Portcullis TrustNet Group, Singapore |
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THE CONFERENCE PROGRAMME – 2005
Saturday, December 3, 2005 |
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| Day 2 | |
| 09.00 – 10.00 | Presentation on Indian Authority for Advance Rulings and panel discussion In the presence of Justice Syed Shah Mohammad Quadri (Chairman – AAR) led by Mukesh Butani (Partner – BMR & Associates, India) |
| 10.00– 10.30 | Coffee |
| Session Three | |
| TRANSFER PRICING GUIDELINES | |
| Chairman | Mukesh Butani, Partner, BMR & Associates, India |
| 10.00 – 11.10 | David Rosenbloom, Caplin & Drysdale, Chartered, United States Transfer Pricing Methodologies Click Here to view the Presentation |
| 11.10 – 11.50 | Carmine Rotondaro, Research Associate at the International Bureau of Fiscal Documentation, The Netherlands The Definition of Associated Enterprises under OECD Model Treaty and the Relationship between Transfer Pricing and Anti-Avoidance Click Here to view the Presentation |
| 11.50 – 12.30 | Alan Granwell, Partner, Ivins, Phillips & Barker, United States Advance Pricing Agreements in Transfer Pricing Click Here to view the Presentation |
| 12.30 – 13.00 | Discussion & Questions |
| 13.00 – 14.00 | Lunch |
| Session Four | |
| TRANSFER PRICING – SOME ISSUES | |
| Chairman | Dinesh Kanabar, Partner, RSM & Co., India |
| 14.00 – 14.40 | Brian Cleave, Member of the Bar of England and Wales and an Honorary Queen’s Counsel, United Kingdom Resolving Transfer Pricing Disputes in Europe through Arbitration Click Here to view the Presentation |
| 14.40 – 15.20 | Robert Anthony, Principal Partner, Anthony & Cie,, France Electronic Commerce and Transfer Pricing Click Here to view the Presentation |
| 15.20 – 16.00 | Jean-Pierre LeGall, Partner, Sullivan & Cromwell, France Transfer Pricing and Recharacterisation of Subsidiaries into Permanent Establishments Click Here to view the Presentation |
| 16.00 – 16.30 | Discussion and Questions |
| 16.30 – 17.00 | Tea |
| Chairman | T P Ostwal, Partner, Ostwal, Desai & Kothari, India |
| 17.50 – 18.15 | Discussion – Transfer Pricing Rules: Are they Necessary in a Developing Country? A panel discussion with our Conference Chairman, Professor Klaus Vogel, and the Special Speaker, Professor Hubert Hamaekers, and other conference speakers |
| 18.15 – 18.30 | Concluding Remarks – Roy Rohatgi Vote of Thanks – Dr. N M Kondap (Vice President, BMA) |
| 18.30 | End of Conference |
