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17th Annual International Taxation
December 1-3, 2011
ITC Maratha Hotel, Mumbai, India

World's International Tax Experts meet at the 17th International Taxation Conference in Mumbai on December 1-3, 2011

In early December the world tax community will beat a path to Mumbai for the 17th annual International Tax Conference organised by the Foundation for International Taxation. This year will be the 17th annual conference. As a truly international conference they have invited over forty speakers and panellists of which over half are from abroad. As in previous years, the wide range of topics and expert speakers should meet the expectations of most of the conference delegates.

The Foundation (FIT) is a registered educational charitable trust in India established to promote the knowledge and understanding of international taxation. Besides this conference, FIT promotes the study of international and comparative tax laws through training, publications, and allied activities dealing with international tax issues. The conference director is Professor Rohatgi. He retired as a worldwide partner in the accounting firm, Arthur Andersen in the mid-nineties after nearly 25 years with the firm. In the eighties, he spent several years in Mumbai where he established the Indian affiliated firm of Andersen. He is a visiting professor in international taxation at several universities, and is author of the acclaimed book "Basic International Taxation." He started the Mumbai conference in 1995.

At first, the conference was a pioneer, being the only conference of its nature in India. Over the years, it has established itself as one of the leading tax conferences in the world, and today this technical conference draws attendance upwards of 600 high level attendees, fully one-third from outside India. Reflecting with satisfaction over the conference's growth over the years, Professor Rohatgi said: "I'm proud and delighted the conference has grown so well, and become known all over the world. It is not just an Indian tax conference, but truly international, simply being held in India. Several of us who have worked on it over the years couldn't be happier." And as to its foremost achievements: "I'm most proud of several achievements-

  1. that we can draw from the best international speakers around the world;
  2. that all the "big five" firms in India are working together cooperatively for our conference; and
  3. that the Revenue Department participates on a cooperative basis, not only attending, but actively participating.
It has truly become a leading technical conference on the subject in the world with the primary objective to promote the knowledge of this highly complex and important subject in the global economy of today".

This year's three-day conference will be held at the ITC Maratha Hotel, starting December 1st.

Day One (1st December 2011)
Day One will address the expected Indian Direct Tax Code in the morning. This session includes ten eminent tax professionals, who will give their views on some key issues, concerns and solutions in the DTC proposals. They include Mr R N Dash, Director General of International Taxation in India, and two key members of the DTC Task Force of the Ministry of Finance. In the afternoon, there are concurrent sessions on International Tax Structuring for Investing Abroad and Indirect Taxation Developments in India. The afternoon session will address presentations on tax structuring for investing in Canada, Malaysia, and in and through Singapore. It also includes a presentation on some of the recent tax developments affecting inbound and outbound Indian investment generally. As an option, the afternoon attendees may attend an impressive series of presentations on Indirect Taxation, which will be chaired by Satya Poddar, who heads the indirect tax practice at Ernst & Young in India. Prior to joining E&Y in India, in 2005, he was with the firm in Toronto, Canada, since 1987; and before that he worked on GST issues and tax reforms with the Canadian government. There are five experts (Indian and foreign) giving their views on the issues affecting the design and implementation of the proposed GST in India.

Day Two (2nd December 2011)
The theme of Day two is International Tax Anti-avoidance Rules. It is addressed by a distinguished array of international speakers from around the world, including: Manuel Tron, a leading tax lawyer in Mexico and the current worldwide president of the International Fiscal Association (IFA); Philippe Martin, a tax judge from the Supreme Court in France; R.V. Easwar, President of India's Income Tax Appellate Tribunal, Carol Dunahoo, a well known US tax lawyer with the firm Baker & McKenzie; Brian Cleave, a UK barrister and former Chief Solicitor for Inland Revenue; Stef van Weeghel, a tax partner at PricewaterhouseCoopers and professor of international tax law at the University of Amsterdam, the Netherlands; Luc de Broe, a prominent tax lawyer and university professor in Belgium; and Sanjay Mishra, the India's Competent Authority. The day will conclude with a discussion panel on "Are tax treaty overrides under anti-avoidance rules in domestic tax law justified?" It will be moderated by Roger Wheeler (formerly Chief Tax Officer at General Motors Corporation), currently a consultant with KPMG in the US and co-director of this conference.

A highlight of the second day will be the "Klaus Vogel" Keynote Address, given by Professor Reuven Avi-Yonah, the Irwin I. Cohn Professor of Law, and University of Michigan Law School, United States. Professor Avi-Yonah will speak on the "Current Global Scenario in Anti-avoidance Rules." The keynote address is so-named in memory of the late Professor Klaus Vogel, who was a widely recognized academic expert on aspects of international taxation, particularly on the interpretation of double taxation treaties. A professor of tax law for some 20 years at the University of Munich, he attended the Mumbai Conference several times as speaker and conference chairman, and in 2004 was named honorary President of the Foundation. Professor Vogel passed away in December of 2007.

Conference director Roy Rohatgi remembers Klaus Vogel as a leading scholar on tax treaties, and the author of a classic treatise on "Double Taxation Conventions" which has been widely quoted by the Supreme Court and the Authority for Advanced Rulings in India. More importantly, he was a transformational figure for the Foundation on several fronts. According to Roy, "Klaus gave the Mumbai conference global recognition, and with his involvement other international thought leaders followed him to Mumbai. He also gave us credibility with the likes of OECD and the United Nations, which have now become two of our biggest supporters. Because of his popularity with India tax practitioners, he also attracted the leading Indian tax professionals in the country, who often came to the conferences just to be around Professor Vogel."

Day Three (3rd December 2011)
On Day Three of this year's conference, attendees will have to choose between two outstanding virtually full day programmes. The choice is between International Tax Developments, and Transfer Pricing Trends. The former track consists of a morning session addressing recent developments in the United Nations Model treaty with following speakers: Michael Lennard, Chief of the International Tax Cooperation and Trade Section, United Nations, New York; Anita Kapur, Director General of Income Tax Administration, India; and well-known Indian practitioner T. P. Ostwal, a partner in his firm of T. P. Ostwal & Associates in Mumbai. The afternoon session is devoted to Recent International Tax Developments and includes four eminent international speakers: Nordine Bensouda, General Treasurer, Ministry of Economy and Finance, Morocco; Philippe Malherbe, tax lawyer and professor from Belgium; Miguel Valdes, prominent tax lawyer in Brazil and; Kyung Geun Lee, partner with the tax law firm Yulchon in Korea.

The second track on Day Three is coordinated by Caroline Silberztein, until recently Head of the Transfer Pricing Unit in the OECD's Centre for Tax Policy and Administration and Secretariat to Working Party No. 6 of the Committee on Fiscal Affairs. This Committee is the OECD body in charge of the taxation of multinational enterprises and specifically of transfer pricing guidelines.

Caroline has joined the international law firm Baker & McKenzie as a partner in their Paris office in September 2011. She will lead a panel discussion on "Transfer Pricing: what are the Pressure Points" in the pre-lunch session. The afternoon session includes presentations by Michelle Levac, transfer pricing specialist with the Canada Revenue Agency; Marc Levey, US partner with Baker & McKenzie; Monique van Herksen, partner with Ernst & Young in the Netherlands; Toshio Miyatake, well known tax lawyer in Japan; and Rashmi Saxena Sahni, Commissioner of Income Tax, India with special responsibility for the transfer pricing programme and the proposed advance pricing agreement in India.

Day Three begins and ends with panel discussions. The morning session on "Anti-avoidance Rules - Role of the Judiciary," is coordinated by Roger Wheeler and moderated by the well-known Indian practitioner Mukesh Butani with Harry (Hank) Gutman, an internationally renowned tax lawyer with KPMG in Washington, DC. Hank is a former Chief of Staff for the US Congressional Joint Committee on Taxation, which deals with technical, economic and revenue aspects of tax legislation. To conclude the conference, there will be a question and answer session with the Indian Transfer Pricing Directorate, coordinated by Rashmi Saxena Sahni, and a panel discussion on "Recent International Tax Developments in India," chaired by T. P. Ostwal. This latter panel will be moderated by Bloomberg UTV, India for broadcast on their channel.

The conference also includes this year five special presentations by expert speakers on the role of international financial centres and trusts in managing multinational business operations.

Selected Biographies: Meet Five of the Non-Indian Speakers

Michael Lennard is the Chief, International Tax Cooperation and Trade in the Financing Development Office of the United Nations. His work focuses on ensuring the fairness and workability of international tax rules in developing countries, and encouraging improvements in their tax systems and administrations to achieve sustained development. Previously he was a tax treaty advisor in the OECD in Paris and had worked at the Australian Tax Office.

Reuven Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of the International Tax LL.M Program in the University of Michigan Law School in the United States. As one of the leading tax academics globally, he has served as consultant to the US Treasury and to the OECD on tax competition and presented his views on various international tax issues. Professor Avi-Yonah is a visiting professor at several leading US universities.

Kyung Geun Lee leads the international tax team at Yulchon, a leading law firm in Korea. He is a former Director of the International Tax Division and the Corporate Income Tax Division of the Korean Ministry of Strategy and Finance. During 2005-2006, he served as Vice Chair of the UN Tax Expert Committee and currently participates in its Transfer Pricing Subcommittee as a member from the private sector.

Nordine Bensouda is the General Treasurer for the Kingdom of Morocco. During his career, he has been the General Director of Tax Administration and Chief of the Cabinet for the Ministry of Finance. From 2005-2009, he chaired the UN Committee on Experts on International Cooperation in Tax Matters, and was a member of the IFA Permanent Scientific Committee.

Monique van Herksen is Ernst & Young's Global Head of Transfer Pricing Controversy, based in the Netherlands, and EMEIA Head of Tax Controversy, specializing in Mutual Agreement Procedures and Arbitration. She has taught transfer pricing at several leading universities and participated in several international organizations such as OECD, UN and EU. She is a member of the UN Transfer Pricing-Practical Issues Subcommittee that deals with transfer pricing in developing countries.

The conference dates are December 1-3, 2011 at the ITC Maratha Hotel in Mumbai. For further information, please visit their website at or contact the executive secretary at their Mumbai office by phone (9122 6610 1964) or email (

August 23, 2011

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