| 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
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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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 11.30 – 12.00 |
Roy Saunders, Managing Partner, International Fiscal Services Ltd., United Kingdom
Investing in the European Union
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Here to view the Presentation |
| 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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Here to view the Presentation
|
| 14.30 – 15.00 |
Juan Manuel Idrovo, Partner, Cañón & Cañón, Colombia
Investing in Latin America
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Here to view the Presentation
|
| 15.00 – 15.30 |
Shefali Goradia, Partner, BMR & Associates, India
Investing from India
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Here to view the Presentation
|
| 15.30 – 16.00 |
Pranav Sayta, Partner, Ernst & Young, India
Investing in India
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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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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Here to view the Presentation
|
| 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
|
