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CONFERENCE PROGRAMME
DECEMBER 3-5, 2009
ITC MARATHA HOTEL, MUMBAI, INDIA
Thursday, December 3, 2009
19.00–22.30 Welcome Social Evening – Cocktails & Dinner
THEME: TRANSFER PRICING ISSUES
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 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
 
THIS YEAR CONFERENCE THEME: INTERNATIONAL TAX DEVELOPMENTS & INVESTING ABROAD
DATE: DECEMBER 3–5, 2009; VENUE: ITC MARATHA HOTEL, MUMBAI, INDIA
Click here to download 2009 Conference Brochure in PDF Format

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