| Day 1 |
| 09.00 – 10.00 |
Registration
& Coffee |
| 10.00 – 10.15 |
Welcome to the Conference
Roy Rohatgi (Conference Director) |
| Session One |
| INTERNATIONAL
TAX DEVELOPEMENTS |
| 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 |
| 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 |
| 11.50– 12.25 |
Ned Shelton, Director, Sheltons
(International Tax Counsel), Denmark
Recent Judicial Trends in Tax Treaty Interpretations
|
| 12.25– 12.45 |
Discussion and Questions |
| 12.45– 13.00 |
Session 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, 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 |
| 15.00 – 15.30 |
Girish Dave, Director of Foreign
Taxation (Mumbai), Government of India, India
Indian
Tax Positions under the OECD Model Treaty |
| 15.30 – 16.00 |
Porus Kaka, Advocate, India
Impact of Indian Tax Positions on OECD Model – A Professional
View |
| 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 |
| 19.00 – 22.30 |
Cocktails and Dinner |
CONFERENCE
PROGRAMME – 2009
Saturday, December 5, 2009 |
| Day 2 |
| 09.00 – 10.30 |
Some Recent Legal Decisions on International
Tax Issues in India
A panel discussion led by Mukesh Butani,
Partner, BMR & Associates, India with
selected conference speakers and delegates |
| 10.30 – 11.00 |
Coffee |
Session Three (Option One)
INTERNATIONAL TAX STRUCTURING FOR INVESTING ABROAD |
| Chairman |
Jairaj Purandare, Senior Executive
Director,PricewaterhouseCoopers, India |
| 11.00 – 11.30 |
Richard Weisman,Principal,Baker
& McKenzie,HongKong
Investing in the United
States |
| 11.30 – 12.00 |
Roy Saunders, Managing Partner,
International Fiscal Services Ltd., United Kingdom
Investing in the European Union |
| 12.00 – 12.30 |
Marcus Desax, Partner, Walder
Wyss & Partners Ltd., Switzerland
Investing in Switzerland |
| 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 |
Chinese Speaker: To be advised
Investing in the People’s Republic of China
|
| 14.30 – 15.00 |
Ernie Lai King, Director and
Head, Deneys Reitz Tax Services, South Africa
Investing
in South Africa |
| 15.00 – 15.30 |
Juan Manuel Idrovo, Partner,
Cañón & Cañón, Colombia
Investing in Latin America |
| 15.30 – 16.00 |
Pranav Sayta, Partner, Ernst
& Young, India
Investing in India
|
| 16.00 – 16.30 |
Discussions & Questions
|
| 16.30 – 17.00 |
Tea |
Session Three (Option Two)
TRANSFER PRICING ISSUES |
| 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 |
| 11.30 – 12.00 |
Shyamal Mukherjee, Head of Transfer
Pricing Practice, PricewaterhouseCoopers, India
FAR
(Functions, Assets and Risks) Analysis – Significance and Practical
Considerations |
| 12.00 – 12.30 |
Bob Ackerman, Americas Leader
Transfer Pricing, Ernst & Young, United States
Transfer
Pricing Issues in a Recessionary Economy |
| 12.30 – 13.00 |
Discussion & Questions |
| 13.00 – 14.00 |
Lunch |
Session Four (Option Two)
TRANSFER PRICING ISSUES |
| Chairman |
Samir Gandhi, Head of Transfer
Pricing, Deloittes,India |
| 14.00 – 14.30 |
Michael Murphy, Managing Director,
Alvarez & Marsal Taxand LLC, United States
Business Restructuring – Minimizing Tax Liabilities |
| 14.30 – 15.00 |
Robert Green, Partner, Caplin
& Drysdale, Chartered, United States
Select
Transfer Pricing Problems involved in Intercompany Services
|
| 15.00 – 15.30 |
Alpana Saksena, Director of Income–tax
(Transfer Pricing), Government of India, Mumbai
Recent
Judicial Decisions and Developments in Transfer Pricing in India |
| 15.30 – 16.00 |
Elinore Richardson, Partner,
Borden Ladner Gervais LLP, Canada Transfer Pricing
– A Year in Review |
| 16.00 – 16.30 |
Discussion and 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), Govt. of India, Mumbai and chaired
by the Director General of Foreign Taxes, Government of India |
| 18.00 – 18.55 |
Topic: A current tax issue or decision
A panel discussion with selected conference speakers and
delegates chaired by T.P. Ostwal, Partner, T.P. Ostwal
& Associates, India |
| 18.55 – 19.00 |
Concluding Remarks – Roy Rohatgi |
| 19.00 |
End of the Conference |
