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Presentation
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.

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

CONFERENCE PROGRAMME - 2009
Friday, December 4, 2009

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
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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
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11.50– 12.25 Ned Shelton, Director, Sheltons (International Tax Counsel), Denmark
Recent Judicial Trends in Tax Treaty Interpretations
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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
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15.00 – 15.30 Girish Dave, Director of Foreign Taxation (Mumbai), Government of India, India
Indian Tax Positions under the OECD Model Treaty
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15.30 – 16.00 Pinakin Desai, Partner, Ernst & Young Pvt. Ltd., India
Impact of Indian Tax Positions on OECD Model - A Professional View
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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

CONFERENCE PROGRAMME - 2009
Saturday, December 5, 2009

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
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11.30 – 12.00 Roy Saunders, Managing Partner, International Fiscal Services Ltd., United Kingdom
Investing in the European Union
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12.00 – 12.30 Marcus Desax, Partner, Walder Wyss & Partners Ltd., Switzerland
Investing in Switzerland
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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
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14.30 – 15.00

Juan Manuel Idrovo, Partner, Cañón & Cañón, Colombia
Investing in Latin America
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15.00 – 15.30 Shefali Goradia, Partner, BMR & Associates, India
Investing from India
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15.30 – 16.00 Pranav Sayta, Partner, Ernst & Young, India
Investing in India
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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
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11.30 – 12.00 Shyamal Mukherjee, Head of Transfer Pricing Practice, PricewaterhouseCoopers, (Pvt.)India
FAR (Functions, Assets and Risks) Analysis – Significance and Practical Considerations
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12.00 – 12.30 Bob Ackerman, Americas Leader Transfer Pricing, Ernst & Young, United States
Transfer Pricing Issues in a Recessionary Economy
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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
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14.30 – 15.00 Robert Green, Partner,Skadden, Arps, Slate, Meagher & Flom LLP, United States
Select Transfer Pricing Problems involved in Intercompany Services
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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
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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
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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
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