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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.

2006 CONFERENCE – NOVEMBER 30 & DECEMBER 1-2, 2006
ITC GRAND MARATHA HOTEL, MUMBAI, INDIA

Thursday, November 30, 2006
19.00- 22.00 Welcome Social Evening – Cocktails and Dinner

Friday, December 1, 2006

Day 1
09.00 – 10.00 Registration & Coffee
10.00 – 10.15 Welcome to the conference
Roy Rohatgi
(Conference Director)
Session One
RECENT DEVELOPMENTS
Chairman Sohrab Dastur, Senior Advocate, India
10.15 – 11.45 Special Speaker- Mary Bennett, Head of Division, Tax Treaty, Transfer Pricing & Financial Transactions Division, Organisation for Economic Co-Operation and Development, Paris - Presentation & Questions
Proposed New OECD Rules on Attribution of Profits to Permanent Establishments

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11.45– 12.25 B M Singh, Member (Income Tax), Central Board of Direct Taxes, Government of India
Emerging International Tax Issues in India

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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
CURRENT TAX DEVELOPMENTS IN INDIA
Chairman Jairaj Purandare, Senior Executive Director, PricewaterhouseCoopers (P) Ltd., India
14.00 – 14.30 Punit Shah, Partner and Head of Banking and Financial Services Tax Practice, RSM & Co., India
Recent International Tax Developments involving banks and funds in India
14.30 – 15.00 Gaurav Taneja, National Tax Director, Ernst & Young, India
International Tax Issues involving hybrid entities in India and abroad

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15.00 – 15.30 Rupak Saha, Country Tax Leader, GE India, India
International Tax Issues affecting Financial Services in India
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15.30 – 16.00 Sudhir Kapadia, Partner and Head of Tax Practice, BSR & Co., India
Cross-border Tax Issues concerning Financial Institutional Investors in India
16.00 – 16.30 Tea
16.30 – 17.15 Discussion & Questions

17.15 – 18.00 Special Session: James Fitzgerald, V.P. Tax & Administration, Dell Corporation, United States - Presentation and Questions
Dell Computer: Organization of a Global Production Network – Some International Tax Issues
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18.00 – 19.00 Discussion Session
Chairman: Rashmin Sanghvi, Partner, Rashmin Sanghvi & Associates, India
Topic - " International Tax Issues involving E-Commerce - Probable Solutions"
A panel discussion led by Rashmin Sanghvi with selected conference speakers and delegates (Panel Members: Carol Dunahoo, Jim Fitzgerald, Nishith Desai, V N Srinivasa Rao, B M Singh)
19.00 – 20.30 Cocktails and Dinner
Dinner Hosted by the General Manager, ITC Grand Maratha Sheraton Hotel & Towers, Mumbai, India

CONFERENCE PROGRAMME - 2006
Saturday, December 2, 2006
09.00 – 10.30 Panel Discussion led by Mukesh Butani with selected conference speakers and delegates on recent international tax rulings given by the Indian Authority for Advance Rulings in the presence of our special guest, Justice Syed Shah Mohammed Quadri, Chairman, Authority for Advance Rulings, Government of India (Panel Members: Mary Bennett, Michael Lang, John Prebble, Vijay Mathur) Justice Quadri will also give a brief presentation on his views on certain tax treaty issues for panel discussion.
10.00– 11.00 Coffee
Session Three
SOME INTERNATIONAL TAX ISSUES
Chairman Mukesh Butani, Partner, BMR & Associates, India
11.00 – 11.30 Carol Dunahoo, Partner, Baker & McKenzie LLP, United States
International Taxation of Income from Cross-border Services
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11.30 – 12.00 Ned Shelton, Director, Sheltons (International Tax Counsel), Denmark
International Tax Issues arising from the Use of Derivatives
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12.00 – 12.30 Robert Green, Partner, Caplin & Drysdale, United States
Recent Developments in Dispute Resolution under Tax Treaties

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12.30 – 13.00 Discussion & Questions
13.00 – 14.00 Lunch
Session Four
TREATY INTERPRETATION ISSUES
Chairman Dinesh Kanabar, Partner, RSM & Co., India
14.00 – 14.30 Michael Lang, Professor and Head of the Institute for Austrian and International Tax Law, Vienna University of Economics and Business Administration, Austria
Relevance of Domestic Tax Law in Tax Treaty Interpretations
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14.30 – 15.00 John Prebble, Professor and Barrister, New Zealand
Allocation of Profits under Source and Residence Rules in Tax Treaties
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15.00 – 15.30 Michael Quigley, Senior Tax Partner, White & Case LLP, United States
Transfer Pricing Issues in the United States

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15.30 – 16.00 Discussion and Questions
16.00 – 16.30 Tea
16.30 – 17.30

Discussion Session
Chairman - T P Ostwal,
Partner, T.P. Ostwal & Associates, India
Topic – Transfer Pricing Rules: How Useful are Advance Pricing Agreements?

A panel discussion led by T.P. Ostwal with selected conference speakers and delegates
(Panel members: Robert Green, Michael Quigley, Samir Gandhi, Vispi Patel, Narayan Mehta, Mary Bennett)

17.30 – 18.00 Concluding Remarks – Roy Rohatgi
18.00 End of Conference
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