| Day 1 |
| 09.00 – 10.00 |
Registration
& Coffee |
| 10.00 – 10.15 |
Welcome to the Conference
Roy Rohatgi (Conference Director) |
| Session One |
| SOME SPECIAL
ISSUES IN TRANSFER PRICING |
| Chairman |
Sohrab Dastur, Senior
Advocate, India |
| 10.15 – 11.15 |
Special Speaker: Presentation
and Questions Harry L “Hank” Gutman,
Director, KPMG Tax Governance Institute, United States
Transfer Pricing and Corporate Governance
|
| 11.15– 11.45 |
Robert Ackerman, Americas Leader
Transfer Pricing, Ernst & Young, United States-_ Stand-in
speaker: V N Srinivasa Rao, National Leader of International
Tax Services, Ernst & Young (Pvt.) Ltd., India Transfer
Pricing and Intangible Planning |
| 11.45 – 12.15 |
Garry Stone, Global and US Leader
of the Transfer Pricing Group, PricewaterhouseCoopers, United
States Transfer Pricing for Intercompany Services
|
| 12.15– 12.45 |
Diane Hay, Deputy Director, Corporate
Tax and VAT, UK HM Revenue and Customs
Recent Developments in Transfer Pricing: The UK
HMRC’s Transfer Pricing Group
|
| 12.45– 13.00 |
Discussion & Questions & Session
Chairman’s Remarks |
| 13.00 – 14.00 |
Lunch |
Session Two
TRANSFER PRICING COMPLIANCE AND DISPUTE RESOLUTION |
| Chairman |
Jairaj Purandare, PricewaterhouseCoopers
(P) Ltd., India |
| 14.00 – 14.30 |
Uday Ved, Executive Director
and Head of Tax – KPMG India Issues Involving
Comparability and Profit Methods in Transfer Pricing
|
| 14.30 – 15.00 |
Matthew Frank, Senior Tax Counsel,
General Electric Corpn., United States - Stand-in speaker:
Vijay Iyer, National Transfer Pricing leader, Ernst
& Young (Pvt.) Ltd, India Advance Pricing Agreements
in Transfer Pricing
|
| 15.00 – 15.30 |
Prakash Chandra, Director General
(Foreign Tax Division) Government of India (confirmed) Transfer
Pricing Compliance – A Revenue Perspective
|
| 15.30 – 16.00 |
David Sutherland, Managing Director,
Morgan Stanley Asia, Hong Kong (confirmed) Some
Transfer Pricing Compliance Issues in Asia – A Taxpayers’
Perspective
|
| 16.00 – 16.30 |
Discussion & Questions |
| 16.30 – 17.00 |
Tea |
| 17.00– 18.00 |
Discussion Session
Chairman – Roger Wheeler, former
Head of Tax, General Motors, United States Topic
– Importance of Corporate Governance in Transfer Pricing
A panel discussion led by Roger Wheeler with
selected conference speakers and delegates.
|
| 18.00 – 19.00 |
Presentation by the Netherlands Foreign Investment
Agency Topic – Tax issues in Doing Business
with the Netherlands |
| 20.00 – 21.00 |
Presentation by the Flanders Investment and Trade
Agency, Belgium and AAMILLtd. Topic –
Tax Issues in Doing Business in Belgium
|
| 19.00 – 22.30 |
Cocktails and Dinner |
CONFERENCE
PROGRAMME - 2008
Saturday, December 6, 2008 |
| 09.00 – 10.30 |
Some Recent Legal Decisions on Transfer
Pricing Issues in India
A panel discussion led by Mukesh Butani,
Partner, BMR & Associates, India with
selected conference speakers and delegates
Presentation by V K Mangotra & Alpana Saksena,
Directors of Income-Tax (Transfer Pricing), Mumbai (India)
Issues of Litigation in Transfer Pricing in India
|
| 10.30 – 11.00 |
Coffee |
Session Three
SOME RECENT DEVELOPMENT IN TRANSFER PRICING |
| Chairman |
Dinesh Kanabar, Executive Director,and
Leader of Tax Practice of PricewaterhouseCoopers, India
|
| 11.00 – 11.30 |
Murray Clayson, Global Head of
Tax Practice, Freshfields Bruckhaus Deringer, United Kingdom
PE Attribution Rules and the Transfer Pricing Analogy
|
| 11.30 – 12.00 |
Shikha Gupta, Head- India, General
Electric Corporation, India Recent Developments
in Global Transfer Pricing Documentation
|
| 12.00 – 12.30 |
Shanto Glosh, Director and Principal
Economist, Deloittes, India Cost Contribution Agreements
in Transfer Pricing - Internatioanl Best Practices
|
| 12.30 – 13.00 |
Discussion & Questions |
| 13.00 – 14.00 |
Lunch |
Session Four
TRANSFER PRICING AND BUSINESS RESTRUCTURING |
| Chairman |
Nishith Desai, Founder –
Nishith Desai Associates, India |
| 14.00 – 14.30 |
Caroline Silberztein, Head of
Transfer Pricing Unit, Organisation for Economic Co-operation
and Development, Paris OECD Project on Transfer
Pricing Aspects of Business Restructurings – An Update
|
| 14.30 – 15.00 |
Michael Murphy, Managing Director,
Alvarez & Marsal Taxand LLC, United States - Stand-in
speaker: Shyamal Mukherjee, Head of Transfer Pricing
Practice, PricewaterhouseCoopers (Pvt.) Limited, India
Transfer Pricing Issues in Business Resturcturing
|
| 15.00 – 15.30 |
Heinz-Klaus Kroppen, Europe,
Middle East and Africa Transfer Pricing Leader, Deloitte, Germany
Issue of Locational Savings in Transfer Pricing
|
| 15.30 – 16.00 |
Discussions & Questions
|
| 16.00 – 16.30 |
Tea |
| 16.30 – 17.00 |
Discussion and Questions on current Indian
transfer pricing
Issues with Mr Prakash Chandra and senior transfer pricing officials
|
| 17.00 – 18.75 |
Chairman: T P Ostwal, Partner.
T P Ostwal & Associates, India
Topic – Recent Decision on the Vodafoen
Case in the Mumbai High Court
A panel discussion with selected conference speakers and delegates
|
| 17.45 - 18.00 |
Concluding Remarks – Roy Rohatgi
|
| 18.00 |
End of Conference |