24th INTERNATIONAL TAXATION CONFERENCE
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
ANNUAL CONFERENCE – PROGRAMME AND PRESENTATIONS
December 5 – 7, 2019 – ITC MARATHA HOTEL, MUMBAI
JOINT CONFERENCE OF
THE FOUNDATION FOR INTERNATIONAL TAXATION
THE INTERNATIONAL BUREAU OF FISCAL DOCUMENTATION (IBFD)
IN COOPERATION WITH THE ORGANIZATION
FOR ECONOMIC COOPERATION & DEVELOPMENT, PARIS
THEME: GLOBAL TAX REFORM: AN AMBITIOUS DREAM?
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DAY 1 : 5 DECEMBER 2019 (THURSDAY) |
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| OFFICIAL OPENING | |
| 08.00 – 20.00 | Registration |
| 08.45 – 09.15 | Welcome by Joint Conference Directors: – Roy Rohatgi, Managing Trustee, Foundation for International Taxation, India – Belema Obuoforibo, Director of Knowledge Centre, IBFD, The Netherlands |
| 09.15 – 09.30 | Special Address: Murray Clayson, President, International Fiscal Association Click Here to view the Presentation  |
| 09.30 – 10.00 | TEA BREAK |
| Plenary Session: Political Economy: Context & New Approach | |
| Chairman | Porus Kaka, former President, International Fiscal Association-Worldwide: 2012-17 |
| 10.00 – 10.30 | “Klaus Vogel” Speaker: Pascal Saint-Amans, Director, Centre for Tax Policy and Administration, OECD, Paris: Stand – in : Grace Perez- Navarro, Deputy Director, Centre for Tax Policy and Administration, OECD, Paris Political Economy Context: An Overview of the New Approach |
| 10.30 – 11.00 | Richard Collier, Senior Tax Advisor, OECD, Paris The Unified Approach Click Here to view the Presentation |
| 11.00 – 13.00 | New Taxing Rights: Pillar I – New Nexus and New Allocation of Taxing Rights Panel Discussion led by Melissa Dejong, OECD. Panelists: Richard Collier, OECD – Guglielmo Maisto, Italy – Akhilesh Ranjan, India – Mike Williams, UK with concluding remarks from the Session Chairman. |
| 13.00 – 14.00 | LUNCH BREAK |
| Session: | |
| Political Economy Context & New Approach | |
| Chairman | Belema Obuoforibo, Director of Knowledge Centre, IBFD, The Netherlands |
| 14.00 – 15.30 | The New Taxing Rights – Pillar II – Minimum Tax based on Proposed Global Anti-Base Erosion Tax: Implementation includes use of withholding taxes & thresholds/carve-outs and compatibility with treaties and other obligations. Panel Discussion led by Melissa Dejong, OECD. Panelists: Rasmi Ranjan Das, India – Annet Wanyana Oguttu, South Africa – David Stewart, USA. Click Here to view the Presentation |
| Chairman | Sol Picciotto, Professor, ICTD, UK |
| 15.30 – 17.00 | The New Taxing Rights – Nexus and Tax Treaty Implications: Operational Issues Panel Discussion led by Robert Danon, Switzerland. Panelists: – Richard Collier, OECD –Jeffrey Owens, UK – Akhilesh Ranjan, India. |
| 17.00 – 17.30 | TEA BREAK |
| Session: | |
| New Taxing Rights – Next Steps | |
| Chairman | Sol Picciotto, Professor, ICTD, UK |
| 17.30 – 19.00 | Concluding Discussion. Panelists: Rajat Bansal, India – Vidushi Gupta, India – Ridha Hamzaoui, IBFD – Grace Perez-Navarro, OECD – Michael Kobetsky, Australia, with questions and comments from the speakers and from the floor. |
| 19.00 – 22.00 | NETWORKING DINNER |
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DAY 2 : 6 DECEMBER 2019 (FRIDAY) |
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| Plenary Session: Impact of Recent Developments on Indian Tax Policy and Objectives | |
| Chairman | Dinesh Kanabar, CEO., Dhruva Advisors LLP, India |
| 09.00 – 09.15 | Session Chairman’s Introductory Remarks |
| 09.15 – 09.45 | Akhilesh Ranjan, Member, Central Board of Direct Taxes, India Recent Developments in International and Domestic Taxation in India |
| 09.45 – 11.00 | Indian Direct Tax Code Update: Recent Developments in International Tax Law and Practice in India Panel Discussion led by Dinesh Kanabar. Panelists: Daksha Baxi – Ketan Dalal – Gautam Doshi – Hitesh D. Gajaria – Pranav Sayta (all from India). |
| 11.00 – 11.30 | TEA BREAK |
| Chairman | Belema Obuoforibo, Director of Knowledge Centre, IBFD, The Netherlands |
| 11.30 – 13.00 | Tax Reforms in Africa Presentation by Ferdinand Nji, Cameroon followed by Panel Discussion led by Annet Oguttu, South Africa. Panelists: Ridha Hamzaoui, IBFD – Mustapha Ndajiwo, Nigeria – Mohamed Ben Mlik, South Africa. Click Here to view the Presentation |
| 13.00 – 13.15 | Book Launch, Digital Taxation – A Holistic View Authors – Rashmin Sanghvi, Naresh Ajwani & Rutvik Sanghvi |
| 13.15 – 14.00 | LUNCH BREAK |
| Plenary Session: (Afternoon) | |
| Chairman | Dr.(C.A) Sunil Moti Lala, Advocate & Trustee, Foundation for International Taxation, Mumbai |
| 14.00 – 14.30 | Sanjay Kapadia, Senior Advisor, KNAV,India Exchange of Information (including on Beneficial Ownership) under Action Thirteen: Some Issues and Comments Click Here to view the Presentation |
| 14.30 – 15.00 | Robert Danon, Professor at University of Lausanne, Switzerland Relevance of Substance in Cross-border Tax Planning Click Here to view the Presentation |
| 15.00 – 15.30 | Grace Perez-Navarro, Deputy Director, Centre for Tax Policy and Administration, OECD, Paris What drives Taxpayer’s willingness to pay taxes? Click Here to view the Presentation |
| 15.30 – 16.00 | Shikha Mehra, Professor & Consultant, India Crypto currencies: Challenges, Risks and Opportunities |
| 16.00 – 16.30 | Vidushi Gupta, Senior Resident Fellow and Team Leader, Vidhi Centre for Legal Policy, India Taxing the Digital Economy in India: The Nexus Rule Click Here to view the Presentation |
| 16.30 – 17.00 | Sam Sim, Research Fellow, SMU Center for Artificial Intelligence, Singapore Going the Way of the Polaroid: Death of the OECD MC Article 9(1) Arm’s Length Principle Click Here to view the Presentation |
| 17.00 – 17.30 | TEA BREAK |
| Session: | |
| Recent International Tax Decisions (Option A) | |
| Chairman | Mukesh Butani, Trustee, Foundation for International Taxation, India |
| 17.30 – 19.30 | Post BEPS Treaties and Tax Certainty under Multilateral Instrument: Can Tax Certainty be achieved with a Policy of Tax Abuse Prevention in post BEPS World? Presentation by Robert Danon, Professor, Lausanne University, Switzerland & Chair, Permanent Scientific Committee, International Fiscal Association, followed by Panel Discussion led by Rajesh Ramloll, Mauritius. Panelists: Bijal Ajinkya, India – Sriram Govind, Vienna – Ridha Hamzaoui, IBFD – Rajesh Simhan, India Click Here to view the Presentation |
| Session: | |
| Attribution of Profits in India and Abroad – Recent Developments under Tax Treaties (Option B) | |
| Chairman | Vijay Mathur, Senior Tax Advisor, PricewaterhouseCoopers, India |
| 17.30 – 19.30 | Presentation by Radhakishan Rawal, Partner, Deloitte, Haskins & Sells LLP on Attribution of Profits under UN Model followed by Panel Discussion led by Jairaj Purandare, India. Panelists. Rasmi Ranjan Das, India – Kuntal Dave, India – Akshay Kenkre, India – Amar Mehta, Canada – PVSS Prasad, India. Click Here to view the Presentation Click Here to view the Presentation |
| 19.30 – 22.00 | NETWORKING DINNER |
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DAY 3 : DECEMBER 7, 2019 (SATURDAY) |
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| Session: | |
| Tax Dispute Resolution (Morning) | |
| Chairman | Mukesh Butani Trustee, Foundation for International Taxation, India |
| 09.00 – 10.30 | Resolution of Tax Disputes in the new International Tax Order Panel Discussion led by Mukesh Butani, India. Panelists: Rajat Bansal, India – Jeffrey Owens, UK – Rajesh Ramloll, Mauritius Click Here to view the Presentation Click Here to view the Presentation Click Here to view the Presentation ` |
| 10.30 – 11.00 | Book Launch Title: FEMA Compounding Orders- A Comprehensive Analysis Authors – Hardik Mehta, Harshal Bhuta & Tanvi Vora. |
| 11.00 – 11.30 | TEA BREAK |
| Session: | |
| Global Impact of New Technologies on International Taxation: An Update (Option A) | |
| Chairman | Clive Baxter, Maersk Group, Chief Tax Counsel , Denmark |
| 11.30 – 13.30 | Likely Implications of the New Technologies on future Tax Policy and Administration: An Update. Presentation by Professor Jeffrey Owens, Vienna WU, Austria on their Impact on (i) Tax Systems, (ii) Tax Administrations, and (iii) Tax Policies of the Future, followed by Panel Discussion led by Shikha Mehra, India. Panelists: Ranjana Gupta, New Zealand – Sam Sim, Singapore Click Here to view the Presentation Click Here to view the Presentation Click Here to view the Presentation |
| Session: | |
| Impact of New Taxing Rights: A Critical Evaluation of OECD PROPOSALS in India (Option B) | |
| Chairman | Ola Ostazewska, Head, European Knowledge Group, IBFD |
| 11.30 – 12.00 | Milind Kothari, Managing Partner, BDO India LLP, India An Industry Perspective of the New Taxing Rights in india Click Here to view the Presentation |
| 12.00 – 12.30 | Kuntal Dave, Proprietor, Nanubhai Desai & Co., Mumbai Impact on Investments in India: Challenges and Opportunities Click Here to view the Presentation |
| 12.30 – 13.00 | Dr. (C.A) Sunil Moti Lala, Advocate & Trustee, Foundation for International Taxation, Mumbai International Tax Precedents in India with Global Significance Click Here to view the Presentation |
| 13.00 – 13.30 | Questions and Answers & Concluding Remarks by Session Chairman. |
| 13.30 – 14.30 | LUNCH BREAK |
| Session: | |
| Transfer Pricing Developments (Option A) | |
| Chairman | T P Ostwal, Managing Partner, T P Ostwal & Associates LLP, India |
| 14.30 – 16.30 | Case Study on Transfer Pricing based on BEPS Panel Discussion led by Rahul Mitra, India. Panelists: Vijay Iyer, India – Michael Kobetsky, Australia – Sanjeev Sharma, India – Mark van Casteren, The Netherlands. Click Here to view the Presentation |
| Session: | |
| The Transparency Agenda: Some Current Issues (Option B) | |
| Chairman | Ola Ostazewska, Head, European Knowledge Group, IBFD |
| 14.30 – 16.30 | The Transparency Agenda: Transparency against the Backdrop of Taxpayer Rights and Data Protection Panel Discussion led by Rajesh Ramloll, Mauritius Panelists: Walter Andreoni, Italy – Julia de Jong, IBFD – Alessandro Turina, IBFD. Click Here to view the Presentation Click Here to view the Presentation Click Here to view the Presentation |
| 16.30 – 17.00 | TEA BREAK |
| Session: | |
| Tax Administration under the Emerging International Tax Order for Developing Countries: Challenges and Prospects | |
| Chairman | Rachel Saw, Head – Asia Pacific, IBFD, Malaysia |
| 17.00 – 17.30 | Annet Wanyana Oguttu, Professor of Tax Law, Pretoria University, South Africa. CbC Reporting: Implementation Challenges for Developing Countries – As the 2020 Inclusive Framework Review Looms, Is Public CbC Reporting the Way to Go? Click Here to view the Presentation |
| 17.30 – 18.30 | Reallocation of Taxing Rights under the OECD Proposals: Impact on Developing Countries. Panel Discussion led by Rajesh Ramloll,Mauritius. Panelists: Mukesh Butani,, India –Julia de Jong, IBFD – Ameya Kunte, India – Sol Picciotto, UK |
| 18.30 – 18.45 | CLOSING REMARKS: Belema Obuoforibo (IBFD) – Roy Rohatgi (FIT) |
