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INTERNATIONAL TAXATION
CONFERENCE
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
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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 |
| 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
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| 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
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| 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
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| 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
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| 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
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| 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 |
CONFERENCE PROGRAMME - 2006
Saturday, December 2, 2006
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| 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
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| 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
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| 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)
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| 17.30 – 18.00 |
Concluding Remarks – Roy Rohatgi |
| 18.00 |
End of Conference |
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