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.
Conference Programme 2009
Thursday, December 3, 2009
| PRE-CONFERENCE SESSION | |
| 12.00 – 13.00 | Lunch for Conference Delegates |
| 13.00 – 15.30 | Proposed Direct Tax in India – Briefing and Comments by selected international tax experts in India and abroad. |
| 15.30 – 16.00 | Tea |
| 16.00 – 17.30 | Sponsored session – Multiconsult Ltd., Mauritius (a member of CIM Group) Topic – Mauritius Perspective – An Update on its Legal & Regulatory Framework Click Here to view the Presentation  |
| 19.00 – 22.30 | Welcome Social Evening – Cocktails & Dinner at the ITC Maratha Hotel, Mumbai |
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CONFERENCE PROGRAMME – 2009 |
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| Day 1 | |
| 09.00 – 10.00 | Registration & Coffee |
| 10.00 – 10.15 | Welcome to the Conference Roy Rohatgi (Conference Director) |
| Session One | |
| INTERNATIONAL TAX DEVELOPMENT | |
| Chairman | Sohrab Dastur, Senior Advocate, India |
| 10.15 – 11.15 | “Klaus Vogel” Speaker – Presentation and Questions Arvid Skaar, International Tax Lawyer and Author, Norway Recent Developments in Permanent Establishment and Attribution Rules Click Here to view the Presentation |
| 11.15– 11.50 | Michael Lang, Professor and Head of the Institute for Austrian & International Tax Law, WU, Austria Beneficial Ownership Concept in Tax Treaties Click Here to view the Presentation |
| 11.50– 12.25 | Ned Shelton, Director, Sheltons (International Tax Counsel), Denmark Recent Judicial Trends in Tax Treaty Interpretations Click Here to view the Presentation |
| 12.25– 12.45 | Discussion & Questions |
| 12.45– 13.00 | Sessions Chairman’s Remarks |
| 13.00– 14.00 | Lunch |
| Session Two | |
| ISSUES AFFECTING SOURCE BASED TAXATION | |
| Chairman | Dinesh Kanabar, Executive Director and Leader of Tax Practice of PricewaterhouseCoopers(Pvt.) Ltd., India |
| 14.00 – 15.00 | Richard Vann, Challis Professor of Law, University of Sydney, Australia Allocation of Taxing Rights to Source Countries under Model Treaties Click Here to view the Presentation |
| 15.00 – 15.30 | Girish Dave, Director of Foreign Taxation (Mumbai), Government of India, India Indian Tax Positions under the OECD Model Treaty Click Here to view the Presentation |
| 15.30 – 16.00 | Pinakin Desai, Partner, Ernst & Young Pvt. Ltd., India Impact of Indian Tax Positions on OECD Model – A Professional View Click Here to view the Presentation |
| 16.00 – 16.30 | Discussion & Questions |
| 16.30 – 17.00 | Tea |
| 17.00 – 18.00 | Discussion session chaired by Roger Wheeler, former Tax Head – General Motors, and Marcus Desax, President of the International Fiscal Association, The Netherlands Allocation of Taxing Rights under Model Treaties – Are they equitable? |
| Sponsored Session | |
| 18.00 – 19.00 | Investing in Canada Jointly sponsored by Borden Ladner Gervais LLP & Stikeman Elliott LLP, Canada Click Here to view the Presentation by Elinore Richardson |
| 19.00 – 22.30 | Cocktails & Dinner |
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CONFERENCE PROGRAMME – 2009 |
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| Day 2 | |
| 09.00 – 10.30 | Topic – Advance Pricing Agreements & Compliance Issues A panel discussion led by Roger Wheeler, former Tax Head – General Motors and Mukesh Butani, Partner, BMR & Associates, India in the presence of Craig Sharon, Director of the APA Program at the Internal Revenue Service in the United States and senior members of the Indian Revenue Service |
| 10.30 – 11.00 | Coffee |
| Session Three (Option One) | |
| INTERNATIONAL TAX STRUCTURING FOR INVESTING ABROAD | |
| Chairman | Jairaj Purandare, Senior Executive Director,PricewaterhouseCoopers, (Pvt.) Ltd.India |
| 11.00 – 11.30 | Richard Weisman, Principal, Baker & McKenzie, HongKong Investing in the United States Click Here to view the Presentation |
| 11.30 – 12.00 | Roy Saunders, Managing Partner, International Fiscal Services Ltd., United Kingdom Investing in the European Union Click Here to view the Presentation |
| 12.00 – 12.30 | Marcus Desax, Partner, Walder Wyss & Partners Ltd., Switzerland Investing in Switzerland Click Here to view the Presentation |
| 12.30 – 13.00 | Discussion & Questions |
| 13.00 – 14.00 | Lunch |
| Session Four (Option One) | |
| INTERNATIONAL TAX STRUCTURING FOR INVESTING ABROAD | |
| Chairman | Nishith Desai, Founder – Nishith Desai Associates, India |
| 14.00 – 14.30 | Lewis Lu, Partner, KPMG, China Investing in the People’s Republic of China Click Here to view the Presentation |
| 14.30 – 15.00 | Juan Manuel Idrovo, Partner, Cañón & Cañón, Colombia Investing in Latin America Click Here to view the Presentation |
| 15.00 – 15.30 | Shefali Goradia, Partner, BMR & Associates, India Investing from India Click Here to view the Presentation |
| 15.30 – 16.00 | Pranav Sayta, Partner, Ernst & Young, India Investing in India Click Here to view the Presentation |
| 16.00 – 16.30 | Discussion & Questions |
| 16.30 – 17.00 | Tea |
| Session Three (Option Two) | |
| TRANSFER PRICING ISSUE | |
| Chairman | Uday Ved, Executive Director and Head of Tax – KPMG, India |
| 11.00 – 11.30 | Matthew Frank, Senior Tax Counsel, Transfer Pricing, General Electric Corporation, United States Bilateral v Unilateral Advance Pricing Agreements – Some Issues Click Here to view the Presentation |
| 11.30 – 12.00 | Shyamal Mukherjee, Head of Transfer Pricing Practice, PricewaterhouseCoopers, (Pvt.)India FAR (Functions, Assets and Risks) Analysis – Significance and Practical Considerations Click Here to view the Presentation |
| 12.00 – 12.30 | Bob Ackerman, Americas Leader Transfer Pricing, Ernst & Young, United States Transfer Pricing Issues in a Recessionary Economy Click Here to view the Presentation |
| 12.30 – 13.00 | Discussion & Questions |
| 13.00 – 14.00 | Lunch |
| Session Four (Option Two) | |
| TRANSFER PRICING ISSUE | |
| Chairman | Samir Gandhi, Head of Transfer Pricing, Deloittes,India |
| 14.00 – 14.30 | Michael Murphy, Managing Director, Alvarez & Marsal Taxand LLC, United States (Stand-in Speaker: Darpan Mehta, BMR & Associates, India) Business Restructuring – Minimizing Tax Liabilities Click Here to view the Presentation |
| 14.30 – 15.00 | Robert Green, Partner,Skadden, Arps, Slate, Meagher & Flom LLP, United States Select Transfer Pricing Problems involved in Intercompany Services Click Here to view the Presentation |
| 15.00 – 15.30 | Alpana Saksena, Director of Income–tax (Transfer Pricing), Government of India, Mumbai, India Recent Judicial Decisions and Developments in Transfer Pricing in India Click Here to view the Presentation |
| 15.30 – 16.00 | Elinore Richardson, Partner, Borden Ladner Gervais LLP, Canada and Al Meghji, Partner, Osler, Hoskin & Harcourt LLP, Canada Transfer Pricing – A Year in Review Click Here to view the Presentation by Elinore Richardson & Al Megji |
| 16.00 – 16.30 | Discussion & Questions |
| 16.30 – 17.00 | Coffee Break |
| Final Session (Joint) | |
| 17.00 – 18.00 | Question and Answer session with the Transfer Pricing Directorate, Government of India coordinated by Mr V. K. Mangotra, Director of Income–tax (Transfer Pricing), Government of India, Mumbai. |
| 18.00 – 18.55 | Topic – Proposed Direct Tax Code in India A panel discussion with selected conference speakers and delegates chaired by T.P. Ostwal, Partner, T.P. Ostwal & Associates, India, in the presence of Mr S.S.N. Moorthy, Chairman, Central Board of Dorect Taxes, India.. The session was moderated by Govindraj Ethiraj, editor-in-chief of Bloomberg UTV, India for broadcast on their channel. |
| 18.55 – 19.00 | Concluding Remarks – Roy Rohatgi |
| 19.00 | End of Conference |
