INTERNATIONAL TAXATION CONFERENCE
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
December 3 – 5, 2015 – ITC Maratha Hotel, Mumbai
Jubilee Conference Programme 2015
THEME : BEPS AND BEYOND BEPS: IMPACT AND NEXT STEPS
VENUE: ITC MARATHA
Day 1 – DECEMBER 3, 2015 (THURSDAY) | |
08.00 – 20.00 | Registration |
09.00 – 09.20 | Opening Remarks by Professor Roy Rohatgi, Conference Director |
Chairman | Sohrab Dastur, Senior Advocate, India |
09.20 – 10.00 | Porus Kaka, President – International Fiscal Association Worldwide Special Address |
10.00 – 10.15 | Short Break |
Plenary Session : | |
The G20 Agenda: Base Erosion and Profit Shifting | |
10.15 – 11.00 | “Klaus Vogel” Speaker: Jeffrey Owens, Professor & Director of the Global Tax Policy Center, WU, Austria (former Director, OECD, Paris) followed by Questions The G20 BEPS Agenda: What Heads of Government decided in November 2015? Click Here to view the Presentation |
11.00 – 11.30 | Pasquale Pistone, Professor at Vienna WU and University of Salerno (Italy) and Academic Chairman of International Bureau for Fiscal Documentation, Amsterdam Tax and good Governance: Making the Link between Tax Evasion and Avoidance and Aggressive Tax Planning Click Here to view the Presentation |
11.30 – 12.00 | Richard Vann, Challis Professor, University of Sydney Minimizing and Resolving International Tax Disputes post BEPS Click Here to view the Presentation |
12.00 – 12.30 | Peter H Blessing, Partner, Washington National Group, KPMG, United States Tax Challenges of Digital Economy under BEPS Click Here to view the Presentation |
12.30 – 13.00 | Session Chairman’s Remarks and Questions and Comments from the floor |
13.00 – 14.00 | Jubilee Lunch |
Plenary Session: | |
Some BEPS Reports and their Recommendations | |
Chairman | Girish Vanvari, Head of Tax, KPMG India |
14.00 – 14.30 | Rajesh Ramloll, Deputy Solicitor General, Republic of Mauritius Transparency and Exchange of Information – Will they suffice to curb Tax Avoidance? Click Here to view the Presentation |
14.30 – 15.00 | Graeme Cooper, Professor, University of Sydney, Australia Treaty Abuse and Anti-avoidance Rules under BEPS Click Here to view the Presentation |
15.00 – 15.30 | Kees van Raad,Professor, International Tax Center Leiden and Of Counsel Loyens and Loeff Permanent Establishment Issues under BEPS |
15.30 – 16.00 | Liselott Kana,Head of International Revenue Administration, Chile Impact of BEPS on Developing Countries and on UN Model Treaty Click Here to view the Presentation |
16.00 – 16.30 | Sim Tzi Yong Sam, Board Member and Vice-Chair of Tax Committee, Tax Executive Institute (Asia Chapter) BEPS: Some Practical Implementation Issues for a Global Company Click Here to view the Presentation |
16.30 – 17.00 | Tea Break |
Session | |
Late Afternoon (Option A) | |
Chairman | Mrs. Anita Kapur, ex-Chairperson, Central Board of Direct Taxes, India |
17.00 – 19.00 | Looking Back and Looking Forward: Celebration or Chaos under BEPS in next 20 Years Panel Discussion led by Jeffrey Owens, United Kingdom.; Panelists: Mukesh Butani, India – Graeme Cooper,, Australia – Pasquale Pistone, Italy – Sol Picciotto, United Kingdom – Kees van Raad, The Netherlands – Richard Vann, Australia – Discussion and Questions followed by Chairperson’s Remarks. |
Session | |
Late Afternoon (Option B) | |
Chairman | Vijay Mathur, Senior Tax Advisor, PricewaterhouseCoopers, India |
17.00 – 19.00 | Role of Tax Administrators in the post BEPS World Panel Discussion led by Vijay Mathur, India; Panelists: Liselott Kana, Chile – Bela Sheth Mao, India – Annet Oguttu, South Africa – Pragya Saksena, India – Attiya Waris, Kenya. Discussion and Questions followed by Chairman’s Remarks. |
19.00 – 22.30 | Networking Dinner |
DAY 2 – DECEMBER 4, 2015 (FRIDAY) |
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Plenary Session: | |
BEPS in India – Impact on Indian Tax Policy and Compliance | |
Chairman | Dinesh Kanabar, Founding Partner, Dhruva Advisors LLP, India |
09.15 – 9.30 | Session Chairman’s Introductory Remarks |
09.30 – 10.00 | Akhilesh Ranjan, Joint Secretary & Competent Authority, India (Stand-in Speaker: Sanjeev Sharma, India) BEPS and Indian Tax Policy Click Here to view the Presentation |
10.00 – 10.30 | Ashutosh Dikshit, Of Counsel BMR & Associates LLP., India BEPS and Indian Tax Practice Click Here to view the Presentation |
10.30 – 11.00 | Mohan Parasaran, former Solicitor General of India BEPS and International Tax Compliance/Disputes Click Here to view the Presentation |
11.00 – 11.30 | Break |
11.30 – 13.00 | Impact of BEPS on Indian Tax Policy, Practice and Compliance Panel Discussion led by Dinesh Kanabar. Panelists: Ashutosh Dikshit – Sunil Gupta – Mohan Parasaran – Rohan Shah – Sanjeev Sharma – Pramila Shrivastav – Ajay Vohra (all from India). Discussion and Questions followed by Chairman’s Remarks |
13.00 – 14.00 | Jubilee Lunch |
Session | |
Global Impact of BEPS and Its Future (Option A) | |
Chairman | Nishith Desai, Founder, Nishith Desai Associates, India |
14.00 – 15.00 | Impact of BEPS on Developed Economies – A Review Panel Discussion led by Bobby Parikh, India. Panelists: Shefali Goradia, India – Vladimir Gidirim, Russia – Shanker Iyer, Singapore – Marc Levey, USA – Jai Purandare,India |
15.00 – 16.00 | Impact of BEPS on Emerging and Developing Economies Panel Discussion led by Ajay Vohra, India. Panelists: Bijal Ajinkya, India – Michael Durst, USA – Milind Kothari, India – Annet Oguttu, South Africa – Malathi Sridharan, India |
16.00 – 16.30 | Discussion and Questions followed by Chairman’s Remarks |
Session | |
Tax and Treaty Compliance (Option B) | |
Chairman | Vipul Jhaveri, Head of Tax, Deloitte Haskins & Sells, India |
14.00 – 14.30 | Uday Ved, former Head of Tax, KPMG, India An Overview of the OECD Base Erosion & Profit Shifting Project: Background and 15 Action Points Click Here to view the Presentation |
14.30 – 15.00 | Michael Lang, Professor & Head of the Institute for Austrian and International Tax Law, WU, Vienna Hybrid Mismatches and CFC Rules to Prevent Abuse Click Here to view the Presentation |
15.00 – 15.30 | Daksha Baxi, Partner, Khaitan & Co., India Measures limiting Base Erosion under BEPS – A Critical Review Click Here to view the Presentation |
15.30 – 16.00 | Sol Picciotto, Emeritus Professor (Lancaster University) & International Centre for Tax and Development (ICTD), United Kingdom Harmful Tax Competition and Base Erosion Click Here to view the Presentation |
16.00 – 16.30 | Michael Lang, Professor & Head of the Institute for Austrian and International Tax Law, WU, Vienna BEPS Compliance – Multilateral Instruments to amend Treaties: Will they work? Click Here to view the Presentation |
16.30 – 17.00 | Break |
Session: | |
Late Afternoon (Option A) | |
Chairman | Gautam Mehra, Head of Tax, PricewaterhouseCoopers, India |
17.00 – 18.00 | Impact of BEPS on Multinational Corporations – Panel discussion led by Bela Sheth Mao,India. Panelists: Clive Baxter, Denmark – Gokul Chaudhri, India – Vladimir Gidirim, Russia – Marc Levey, USA – Rupak Saha, India |
18.00 – 19.00 | New BEPS Obligations for Multinational Enterprises Panel Discussion led by Rajesh Simhan, India. Panelists: Joshua D Odintz, USA – Pinky Mehta, India – Jai Purandare,India – Kees van Raad, The Netherlands – Attiya Waris, Kenya. |
19.00 – 19.30 | Discussion and Questions followed by Chairman’s Remarks |
Session: Late Afternoon (Option B) | |
Chairman | V. Lakshmikumaran, Managing Partner, Lakshmikumaran & Sridharan, India |
17.00 – 18.00 | Is Place of Effective Management (POEM) Suitable for Determining Corporate Tax Residence Panel Discussion led by Shefali Goradia, India. Panelists: Daksha Baxi, India – Mahesh Kumar, India – Nilesh Kapadia, India – Michael Lang, Austria – Pragya Saksena, India |
18.00 – 19.00 | Framework for new GST Tax in India – A Quick Update Panel Discussion led by Sachin Menon, India. Panelists: Prashant Deshpande, India – Sujit Ghosh, India – Satya Poddar, India – Rohan Shah, India. |
19.00 – 19.30 | Discussion and Questions followed by Chairman’s Remarks |
19.30 – 22.30 | Networking Dinner |
Day 3 – DECEMBER 5, 2015 (SATURDAY) |
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Special Session: Morning | |
Chairman & Guest of Honour | Justice V S Sirpurkar, Chairman, Authority for Advance Rulings, India |
09.00 – 09.15 | Welcome and Introduction: Justice Sirpurkar by Mukesh Butani (Session Chairman) & Pranav Sayta, India |
09.15 – 10.00 | Tax Disputes and their Resolution under BEPS? Will they work? Panel Discussion led by Mukesh Butani,Managing Partner, BMR Legal, India. Panelists:Arvind Datar, India – Daniel Erasmus, South Africa – Pramod Kumar, India – Jeffrey Owens, United Kingdom – Mohan Parasaran, India – Rajesh Ramloll, Mauritius – Pranav Sayta, India Click Here to view the Presentation Click Here to view the Presentation |
10.00 – 10.20 | Keynote Speaker: Justice V S Sirpurkar |
10.20 – 10.30 | Discussion & Vote of Thanks by Pranav Sayta, Partner, Ernst & Young, India |
10.30 – 11.00 | Break |
Session | |
Tax and Treaty Conflicts (Option A) | |
Chariman | Pranav Sayta, National Leader & Partner, Ernst & Young, India |
11.00 – 13.00 | Future of Digital Economy under BEPS Panel Discussion led by Pranav Sayta,India. Panelists: Peter H. Blessing, USA – Graeme Cooper, Australia – Rakesh Nangia, India – Rashmin Sanghvi, India – Mansi Seth, USA – Rohinton Sidhwa, India. Discussion and Questions followed by Chairman’s Remarks |
Session | |
Transfer Pricing Developments (Option B) | |
Chairman | Rohan Shah, Managing Partner, Economic Laws Practice, India Session coordinated and led by Caroline Silberztein, Baker & McKenzie, France Click Here to view the Presentation |
11.00 – 13.00 | Panel Presentations and Discussion on: Transfer Pricing under BEPS: – Who are the new players? – Is Transfer Pricing a Tax Avoidance Tool? – Transfer Pricing Documentation and Country by Country Reporting – Transfer Pricing Rules to follow Value Creation and not just Risks and Capital? Is Value under BEPS Defined? Panelists: Carol Dunahoo, USA – Michael Durst, USA – Vijay Iyer, India – Sanjiv Malhotra, India – Rohan Phatarphekar, India – G.C. Srivastava, India. Discussion and Questions followed by Chairman’s Remarks |
13.00 – 14.00 | Jubilee Lunch |
Session | |
Other BEPS Action Plans (Option A) | |
Chairman | Jairaj Purandare, Chairman, JMP Advisors, India |
14.00 – 16.00 | Bilateral Taxing Rights under Model Tax Treaties – Would BEPS resolve the Historical Conflicts on Income Allocation between Developed and Developing countries? Panel Discussion led by Rahul Garg, India. Panelists: Akhilesh Ranjan, India – Michael Durst, USA – K. R. Girish, India – Joshua D Odintz, USA – Sol Picciotto, United Kingdom – Sanjeev Sharma, India. Discussion and Questions followed by Chairman’s Remarks |
16.00 – 16.30 | India’s Response to BEPS Question and Answer Session led by Akhilesh Ranjan, Joint Secretary & Competent Authority, India |
Session | |
Transfer Pricing Developments (Option B) | |
Chairman | Gautam Doshi, Group Managing Director, Reliance Anil Dhirubhai Ambani Group, India |
14.00 – 16.00 | Session coordinated and led by Caroline Silberztein, Baker & McKenzie, France. with Anis Chakravarty, Deloitte, India on Future Business Models for Managing Global Companies, including panel presentations and discussions on: – Examples of Scenarios involving intangibles, highlighting BEPS concerns – Intangibles, risk and capital: what is at stake? – Will emerging and developing economies adhere to the new OECD guidance? – How valuable are markets and consumers? – Will there be more disputes and fewer consensuses? Panelists : Carol Dunahoo, USA – Daniel Erasmus, South Africa – Sanjiv Malhotra, India – T P Ostwal, India – Kamlesh Varshney, India. Discussion and Questions followed by Chairman’s Remarks. Click Here to view the Presentation |
16.00 – 16.30 | To be advised |
16.30 – 17.00 | Break |
Joint Final Session: BEPS Project – Will it succeed in achieving its Objectives? | |
Chairman | Richard Vann, Challis Professor, University of Sydney, Australia |
17.00 – 18.55 | Current BEPS Project – Will it succeed with Divergent Global Fiscal Policies? Panel Discussion led by T. P. Ostwal, India. Panelists: Arvind Datar, India – Nishith Desai, India – Gautam Doshi, India – Bobby Parikh, India – Kees van Raad, The Netherlands – Girish Vanvari, India. |
18.55 – 19.00 | Professor Roy Rohatgi: Concluding Remarks |