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.
2006 CONFERENCE – NOVEMBER 30 & DECEMBER 1-2, 2006
ITC GRAND MARATHA HOTEL, MUMBAI, INDIA
Thursday, November 30, 2006
19.00- 22.00 Welcome Social Evening – Cocktails and Dinner
Friday, December 1, 2006
| Day 1 | |
| 09.00 – 10.00 | Registration & Coffee |
| 10.00 – 10.15 | Welcome to the conference Roy Rohatgi (Conference Director) |
| Session One | |
| RECENT DEVELOPMENTS | |
| Chairman | Sohrab Dastur, Senior Advocate, India |
| 10.15 – 11.45 | Special Speaker- Mary Bennett, Head of Division, Tax Treaty, Transfer Pricing & Financial Transactions Division, Organisation for Economic Co-Operation and Development, Paris – Presentation & Questions Proposed New OECD Rules on Attribution of Profits to Permanent Establishments Click Here to view the Presentation  |
| 11.45– 12.25 | B M Singh, Member (Income Tax), Central Board of Direct Taxes, Government of India Emerging International Tax Issues in India 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 | |
| CURRENT TAX DEVELOPMENTS IN INDIA | |
| Chairman | Jairaj Purandare, Senior Executive Director, PricewaterhouseCoopers (P) Ltd., India |
| 14.00 – 14.30 | Punit Shah, Partner and Head of Banking and Financial Services Tax Practice, RSM & Co., India Recent International Tax Developments involving banks and funds in India |
| 14.30 – 15.00 | Gaurav Taneja, National Tax Director, Ernst & Young, India International Tax Issues involving hybrid entities in India and abroad Click Here to view the Presentation |
| 15.00 – 15.30 | Rupak Saha, Country Tax Leader, GE India, India International Tax Issues affecting Financial Services in India Click Here to view the Presentation |
| 15.30 – 16.00 | Sudhir Kapadia, Partner and Head of Tax Practice, BSR & Co., India Cross-border Tax Issues concerning Financial Institutional Investors in India |
| 16.00 – 16.30 | Tea |
| 16.30 – 17.15 | Discussion & Questions |
| 17.15 – 18.00 | Special Session: James Fitzgerald, V.P. Tax & Administration, Dell Corporation, United States – Presentation and Questions Dell Computer: Organization of a Global Production Network – Some International Tax Issues Click Here to view the Presentation |
| 18.00 – 19.00 | Discussion Session Chairman: Rashmin Sanghvi, Partner, Rashmin Sanghvi & Associates, India Topic – ” International Tax Issues involving E-Commerce – Probable Solutions” A panel discussion led by Rashmin Sanghvi with selected conference speakers and delegates (Panel Members: Carol Dunahoo, Jim Fitzgerald, Nishith Desai, V N Srinivasa Rao, B M Singh) |
| 19.00 – 20.30 | Cocktails and Dinner Dinner Hosted by the General Manager, ITC Grand Maratha Sheraton Hotel & Towers, Mumbai, India |
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CONFERENCE PROGRAMME – 2006 Saturday, December 2, 2006 |
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| Day 2 | |
| 09.00 – 10.30 | Panel Discussion led by Mukesh Butani with selected conference speakers and delegates on recent international tax rulings given by the Indian Authority for Advance Rulings in the presence of our special guest, Justice Syed Shah Mohammed Quadri, Chairman, Authority for Advance Rulings, Government of India (Panel Members: Mary Bennett, Michael Lang, John Prebble, Vijay Mathur) Justice Quadri will also give a brief presentation on his views on certain tax treaty issues for panel discussion. |
| 10.00– 11.00 | Coffee |
| Session Three | |
| SOME INTERNATIONAL TAX ISSUES | |
| Chairman | Mukesh Butani, Partner, BMR & Associates, India |
| 11.00 – 11.30 | Carol Dunahoo, Partner, Baker & McKenzie LLP, United States International Taxation of Income from Cross-border Services Click Here to view the Presentation |
| 11.30 – 12.00 | Ned Shelton, Director, Sheltons (International Tax Counsel), Denmark International Tax Issues arising from the Use of Derivatives Click Here to view the Presentation |
| 12.00 – 12.30 | Robert Green, Partner, Caplin & Drysdale, United States Recent Developments in Dispute Resolution under Tax Treaties Click Here to view the Presentation |
| 12.30 – 13.00 | Discussion & Questions |
| 13.00 – 14.00 | Lunch |
| Session Four | |
| TREATY INTERPRETATION ISSUES | |
| Chairman | Dinesh Kanabar, Partner, RSM & Co., India |
| 14.00 – 14.30 | Michael Lang, Professor and Head of the Institute for Austrian and International Tax Law, Vienna University of Economics and Business Administration, Austria Relevance of Domestic Tax Law in Tax Treaty Interpretations Click Here to view the Presentation |
| 14.30 – 15.00 | John Prebble, Professor and Barrister, New Zealand Allocation of Profits under Source and Residence Rules in Tax Treaties Click Here to view the Presentation |
| 15.00 – 15.30 | Michael Quigley, Senior Tax Partner, White & Case LLP, United States Transfer Pricing Issues in the United States Click Here to view the Presentation |
| 15.30 – 16.00 | Discussion and Questions |
| 16.00 – 16.30 | Tea |
| 16.30 – 17.30 | Discussion Session Chairman – T P Ostwal, Partner, T.P. Ostwal & Associates, India Topic – Transfer Pricing Rules: How Useful are Advance Pricing Agreements? A panel discussion led by T.P. Ostwal with selected conference speakers and delegates (Panel members: Robert Green, Michael Quigley, Samir Gandhi, Vispi Patel, Narayan Mehta, Mary Bennett) |
| 17.30 – 18.00 | Concluding Remarks – Roy Rohatgi |
| 18.00 | End of Conference |
