INTERNATIONAL TAXATION CONFERENCE
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
DECEMBER 1-3, 2011
ITC MARATHA HOTEL, MUMBAI
Conference Programme 2011
THEME: TRANSFER PRICING ISSUES
Thursday, December 1, 2011 – ITC MARATHA
| Day 1 | |
| 08.00 – 20.00 | Registration |
| 10.00 – 10.15 | Welcome to the Conference |
| Session | |
| PROPOSED DIRECT TAX CODE IN INDIA – An Update (A panel presentation) | |
| Chairman | Dinesh Kanabar, KPMG, India |
| 10.15 – 13.00 | Presentations and discussion on the proposed Code. Panel speakers include R. N. Dash, Director General of International Taxation, India, and Sunil Gupta and Ashutosh Dikshit, Commissioners of Taxes, India (members of the Direct Tax Code Task Force in India). Other panelists: Shefali Goradia (Tax Partner, BMR Advisors, India), Akil Hirani (Managing Partner, Majmudar & Co., India), Nihar Jambusaria (Head of Tax, BDO, India), Dev Joory (Director, International Financial Services, Mauritius) Click below to view the Presentation  1. Shefali Goradia, Tax Partner, BMR Advisors, India 2. Akil Hirani, Managing Partner, Majmudar & Co., India 3. Nihar Jambusaria, Head of Tax, BDO, India 4. Dev Joory, Director, International Financial Services, Mauritius 5. Sunil Gupta, Joint Secretary, Tax Policy and Legislation, Ministry of Finance,Delhi |
| 13.00 – 14.00 | Lunch |
| Session | |
| INTERNATIONAL TAX STRUCTURING FOR INVESTING ABROAD | |
| Chairman | Nishith Desai, Founder, Nishith Desai Associates, India |
| 14.00 – 14.30 | Shanker Iyer, Chairman, The Iyer Practice, Singapore Investing in and through Singapore Click Here to view the Presentation |
| 14.30 – 15.00 | Stephen W. Bowman, Partner, Bennett Jones LLP, Canada Investing in Canada Click Here to view the Presentation |
| 15.00 – 15.30 | Veerinderjeet Singh, Managing Director, Tax and Malaysia Sdn. Bhd. Investing in Malaysia Click Here to view the Presentation |
| 15.30 – 16.00 | Girish Vanvari, Partner, KPMG, India Investing in and out of India – Recent Developments Click Here to view the Presentation |
| 16.00 – 16.30 | Natascha Scholten, Director, TMF Group, United Kingdom Tax Advantages of a Foreign Listing Click Here to view the Presentation |
| Session | |
| INDIRECT TAXATION DEVELOPMENTS | |
| Chairman | Satya Poddar, Partner, Ernst & Young, India |
| 14.00 – 14.15 | Satya Poddar, Session Chairman Overview of the proposed GST in India Click Here to view the Presentation |
| 14.15 – 14.30 | Rajeev Dimri, Head- Indirect Taxation, BMR Advisors, India Treatment of Cross-border Transactions Click Here to view the Presentation |
| 14.30 – 14.45 | Chris Needham, Global VAT/GST Leader, General Electric (UK) Planning for GST Implementation Click Here to view the Presentation |
| 14.45 – 15.00 | Piet Vandendriessche, Deloitte Global Indirect Tax Leader, Belgium India’s proposed GST system-Some of the Issues and Challenges Click Here to view the Presentation |
| 15.00 – 16.00 | Panel Discussion on “Issues and Controversies in Design of GST in India” led by Satya Poddar with conference speakers Bela Sheth-Mao (Shell India) and central and state government officials in India |
| 16.00 – 16.30 | Discussion & Questions |
| 16.30 – 17.00 | Tea Break |
| Session | |
| SPECIAL PRESENTATION | |
| Chairman | Kiran Umrootkar, Finance Director, Jacobs Engg., India |
| 17.00 – 18.00 | Jersey Finance: Richard Teather, International tax expert on Offshore Financial Centres Jersey: Designing a GST Click Here to view the Presentation
Sean Costello, Chief Representative Officer, GCC & India, Jersey Finance Patrick Crowley, Country Executive Head, ABN AMRO Bank N.V. Jersey |
| 18.00 – 18.30 | Richard Pease, Solicitor and Counsel, Lenz & Staehelin, Geneva, Switzerland The World of the Society of Trust and Estate Practitioners (STEP) Click Here to view the Presentation |
| 18.30 – 19.00 | Mauritius: Rama Sithanen, Chairman, International Fiscal Services, Mauritius and Deputy Prime Minister and Minister of Finance and Economic Development: 2005 – 2010 Mauritius: An efficient gateway and hub for investment in Africa Click Here to view the Presentation
Harvesh Seegolam, Senior Investment Advisor, Board of Investment, Mauritius |
| 19.00 – 22.30 | Networking Dinner (Supported by Jersey Finance) |
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CONFERENCE PROGRAMME – 2011 |
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| Day 2 | |
| Session | |
| INTERNATIONAL TAX ANTI-AVOIDANCE RULES | |
| Chairman | Sohrab Dastur, Senior Advocate, India |
| 10.00 – 10.15 | Welcome to Plenary Sessions |
| 10.15 – 10.55 | “Klaus Vogel” Speaker: Reuven Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan Law School, United States Current Global Scenario in Anti-avoidance Rules Click Here to view the Presentation |
| 10.55 – 11.30 | Harry L “Hank” Gutman, Director, KPMG Tax Governance Institute, United States Anti-avoidance and Taxpayers’ Rights |
| 11.30 – 12.05 | Philippe Martin, Tax Judge, France Anti-avoidance – A Judicial View Click Here to view the Presentation |
| 12.05 – 12.40 | Discussion & Questions |
| 12.40 – 13.00 | Session Chairman’s Remarks and Questions |
| 13.00 – 14.00 | Lunch |
| Session | |
| INTERNATIONAL TAX ANTI-AVOIDANCE IN PRACTICE AND TAX TREATIES | |
| Chairman | Ketan Dalal, Joint Head of Tax, PricewaterhouseCoopers, India |
| 14.00 – 14.30 | Brian Cleave, UK Barrister and former Chief Solicitor (Inland Revenue), United Kingdom Judicial Anti-avoidance Practice Click Here to view the Presentation |
| 14.30 – 15.00 | Stef van Weeghel, PricewaterhouseCoopers and Professor of International Tax Law, University of Amsterdam, The Netherlands General Anti-avoidance Rules Click Here to view the Presentation |
| 15.00 – 15.30 | Luc De Broe, Professor and Partner, Laga (a Deloitte affiliated fiscal law firm), Belgium Specific Anti-avoidance Rules Click Here to view the Presentation |
| 15.30 – 16.00 | Sanjay Kumar Mishra, Joint Secretary, Finance Ministry, India Anti-avoidance Rules and Tax Treaties in India Click Here to view the Presentation |
| 16.00 – 16.30 | Discussion and Questions |
| 16.30 – 17.00 | Tea Break |
| 17.00 – 18.00 | Joint Panel Session – I : Are treaty overrides under anti-avoidance rules in domestic tax law justified? Discussion session with selected speakers and delegates chaired by Roger Wheeler, (former Tax Head – General Motors). Other panelists: Michael Lennard, Carol Dunahoo, Sanjay Kumar Mishra & Reuven Avi-Yonah |
| Session | |
| SPECIAL PRESENTATION | |
| Chairman | Kiran Umrootkar Finance Director, Jacobs Engg., India |
| 18.00 – 18.30 | Guernsey Finance, Jonathan Hooley Thriving as a compliant Jurisdiction Click Here to view the Presentation |
| 18.30 – 19.00 | Mauritius: Richard Arlove, Managing Director, Abax Corporate Services, Mauritius Mauritius: Gateway to Africa’s Renaissance Click Here to view the Presentation |
| 19.00 – 22.30 | Networking Dinner (Supported byGuernsey Finance) |
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CONFERENCE PROGRAMME – 2011 |
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| Day 3 | |
| 09.00 – 10.30 | Joint Panel Session – II: Anti-avoidance Rules – Role of the Judiciary. A panel discussion led by Mukesh Butani (Managing Partner, BMR Legal, India) and coordinated by Roger Wheeler (former Tax Head – General Motors) with Harry “Hank” Gutman, Director, KPMG Tax Governance Institute as Chairman. Other panelists: Philippe Martin, Brian Cleave & R. N. Dash |
| 10.30 – 11.00 | Coffee Break |
| Option One | |
| INTERNATIONAL TAX DEVELOPMENTS | |
| Session | |
| RECENT DEVELOPMENTS IN THE UNITED NATIONS MODEL TREATY | |
| Chairman | Pranav Sayta, Partner, Ernst & Young, India (Coordinated by Michael Lennard) |
| 11.00 – 11.45 | Michael Lennard, Chief, International Tax Cooperation and Trade Section, United Nations, New York The Revised United Nations Model Tax Convention Click Here to view the Presentation |
| 11.45 – 12.45 | Panel Discussionon “Role of UN Model and its Commentaries” Panelists: Michael Lennard, T. P. Ostwal, Toshio Miyatake & Carol Dunahoo |
| 12.45 – 13.00 | Discussion and Questions |
| 13.00 – 14.00 | Lunch |
| Session | |
| SOME RECENT INTERNATIONAL TAX DEVELOPMENTS | |
| Chariman | M. Lakshminarayanan, Head of Tax, Deloittes, India |
| 14.00 – 14.30 | Nordine Bensouda, General Treasurer, Ministry of Economy and Finance, Morocco Developments in Africa Click Here to view the Presentation |
| 14.30 – 15.00 | Philippe Malherbe, Professor and Advocate, Belgium Developments in Europe Click Here to view the Presentation |
| 15.00 – 15.30 | Miguel Valdes, Machado Associados, Lawyers, Brazil Developments in Latin America Click Here to view the Presentation |
| 15.30 – 16.00 | Kyung Geun Lee, Partner, Yulchon, Korea Developments in Asia (re Korea) Click Here to view the Presentation |
| 16.00 – 16.15 | Kaushik “Kim” Desai, Principal, Chown Dewhurst LLP, United Kingdom Proposed UK Statutory Definition of Tax Residence Click Here to view the Presentation |
| 16.30 – 17.00 | Discussion & Questions |
| 16.30 – 17.00 | Tea Break |
| Option Two | |
| TRANSFER PRICING | |
| Session | |
| TRANSFER PRICING TRENDS(Coordinated by Caroline Silberztein) | |
| Chairman | Uday Ved, Partner, KPMG, India Click Here to view the Presentation |
| 11.00 – 12.40 | Transfer pricing: what are the pressure points? Session led by Caroline Silberztein. Click Here to view the Presentation
Panelists: Marc Levey, Shanto Ghosh, Sanjay Kumar Mishra and Michelle Levac |
| 12.40 – 13.00 | Discussion and Questions |
| 13.00 – 14.00 | Lunch |
| Session | |
| TRANSFER PRICING: COUNTRY EXPERIENCES | |
| Chairman | Shyamal Mukherjee, Partner, PricewaterhouseCoopers, India |
| 14.00 – 14.30 | Canada – Michelle Levac, Transfer Pricing Specialist, Canada Revenue Agency, Canada Click Here to view the Presentation |
| 14.30 – 15.00 | U.S. – Marc Levey, Partner, Baker & McKenzie, United States Click Here to view the Presentation |
| 15.00 – 15.30 | Europe – Monique van Herksen, Partner, Ernst & Young, The Netherlands Click Here to view the Presentation |
| 15.30 – 16.00 | Japan – Toshio Miyatake, Partner, Adachi, Henderson, Miyatake & Fujita, Japan Click Here to view the Presentation |
| 16.00 – 16.30 | India – Rashmi Saxena Sahni, Commissioner of Income Tax, India Click Here to view the Presentation |
| 16.30 – 17.00 | Tea Break |
| Joint Final Session | |
| 17.00 – 18.00 | Question and Answer session with the Transfer Pricing Directorate, Government of India, chaired by the Director General of Income Tax (International), India and coordinated by Rashmi Saxena Sahni, Commissioner Income Tax, India |
| 18.00 – 18.55 | Panel Discussion – Recent International Taxation Developments in India – A panel discussion with selected conference speakers and delegates chaired by T. P. Ostwal (Partner – T P Ostwal & Associates, India). Other panelists are M.Parasaran, Uday Ved, Bijal Ajinkya, Jairaj Purandare & S. Mahalingam. The session will be moderated by Abha Bakaya of Bloomberg UTV, India for broadcast on their channel in India. |
| 18.55 – 19.00 | Concluding Remarks |
