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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.

2005 CONFERENCE – DECEMBER 2-3, 2005 - MUMBAI

Conference Chairman: Klaus Vogel
Conference Director: Roy Rohatgi

Thursday, December 1, 2005 (19.00 – 22.00)

Welcome Social Evening – Cocktails and Dinner

Friday, December 2, 2005

Day 1
09.00 – 10.00 Registration & Coffee
10.00 – 10.15 Welcome to the Conference
Anant Singhania (President, BMA)
Roy Rohatgi (Conference Director)
Session One
TRANSFER PRICING
Chairman Sohrab Dastur, Senior Advocate, India
10.15 – 11.45 Special Speaker: Hubert Hamaekers, former Chairman of the Board of Management of the International Bureau of Fiscal Documentation, Amsterdam, The Netherlands
Recent Developments in International Transfer Pricing
(Presentation & Questions)

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11.45– 12.25 Peter Barnes, Head of Tax, General Electric Corporation, United States
Transfer Pricing Issues in a Large Multinational Company

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12.25 – 12.45

Discussion and Questions

12.45 – 13.00 Session Chairman’s Remarks
13.00 – 14.00 Lunch
Session Two
TRANSFER PRICING IN PRACTICE
Chairman Jairaj Purandare, Senior Executive Director, PricewaterhouseCoopers (P) Ltd., India
14.00 – 14.40 Akhilesh Ranjan, Director (International Taxation), Government of India
Transfer Pricing Rules under Indian Tax Law – A Revenue View

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14.40 – 15.20 Shyamal Mukherjee, Partner, PricewaterhouseCoopers (P) Ltd., India
Transfer Pricing Issues in India - A Practitioner View

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15.20 – 16.00 Vispi T Patel, Partner, Deloitte Haskins & Sells, India
Transfer Pricing Audits – Indian Experience

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16.00 – 16.30 Tea
16.30 – 17.00 Discussion & Questions
17.00 – 17.50 Caroline Silberztein, Organisation for Economic Co-operation & Development, Paris, France
Practical Issues relating to the Choice of Comparables in Transfer Pricing/
(Presentation & Questions)

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18.00– 19.00 Special Session
Chairman - Rashmin Sanghvi, Partner, Rashmin Sanghvi Associates, India
Klaus Vogel, Professor Emeritus, University of Munich, Germany
Tax Treaties - Recent Case Law around the World (Presentation and Questions)
19.00 – 22.00 Cocktails and Dinner
Presentation on Singapore Tax and Trusts by The Portcullis TrustNet Group, Singapore

THE CONFERENCE PROGRAMME - 2005
Saturday, December 3, 2005
Day 2
09.00 – 10.00 Presentation on Indian Authority for Advance Rulings and panel discussion
In the presence of Justice Syed Shah Mohammad Quadri (Chairman – AAR) led by Mukesh Butani (Partner – BMR & Associates, India)
10.00– 10.30 Coffee
Session Three
TRANSFER PRICING GUIDELINES
Chairman Mukesh Butani, Partner, BMR & Associates, India
10.00 – 11.10 David Rosenbloom, Caplin & Drysdale, Chartered, United States
Transfer Pricing Methodologies
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11.10 – 11.50 Carmine Rotondaro, Research Associate at the International Bureau of Fiscal Documentation, The Netherlands
The Definition of Associated Enterprises under OECD Model Treaty and the Relationship between Transfer Pricing and Anti-Avoidance Click Here to view the Presentation
11.50 – 12.30 Alan Granwell, Partner, Ivins, Phillips & Barker, United States
Advance Pricing Agreements in Transfer Pricing

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12.30 – 13.00 Discussion & Questions
13.00 – 14.00 Lunch
Session Four
TRANSFER PRICING – SOME ISSUES
Chairman Dinesh Kanabar, Partner, RSM & Co., India
14.00 – 14.40 Brian Cleave, Member of the Bar of England and Wales and an Honorary Queen’s Counsel, United Kingdom
Resolving Transfer Pricing Disputes in Europe through Arbitration Click Here to view the Presentation
14.40 – 15.20 Robert Anthony, Principal Partner, Anthony & Cie,, France
Electronic Commerce and Transfer Pricing
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15.20 – 16.00 Jean-Pierre LeGall, Partner, Sullivan & Cromwell, France
Transfer Pricing and Recharacterisation of Subsidiaries into Permanent Establishments

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16.00 – 16.30 Discussion and Questions
16.30 – 17.00 Tea
Chairman

T P Ostwal, Partner, Ostwal, Desai & Kothari, India

17.50 – 18.15 Discussion – Transfer Pricing Rules: Are they Necessary in a Developing Country?
A panel discussion with our Conference Chairman, Professor Klaus Vogel, and the Special Speaker, Professor Hubert Hamaekers, and other conference speakers
18.15 – 18.30 Concluding Remarks – Roy Rohatgi
Vote of Thanks – Dr. N M Kondap
(Vice President, BMA)
18.30 End of Conference
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