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Commemorative Issue - Conference 2017
Compendium of Transfer Pricing and International Tax Rulings Version 1
Free Reference Library
International Taxation Conference - 2018
THEME: BEPS AND BEYOND BEPS : RECENT GLOBAL DEVELOPMENTS
POST RATIFICATION OF MULTILATERAL INSTRUMENT (MLI)


DAY ONE: DECEMBER 6, 2018 (THURSDAY)

08.00 – 20.00 Registration
08.45 – 09.15 Opening Remarks: Roy Rohatgi, Conference Director,Foundation for International Taxation, India
09.15 – 09.45 Welcome: Belema Obuoforibo, Director of Knowledge Centre, International Bureau of Fiscal Documentation, The Netherlands
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09.45 – 10.00 Special Address: Murray Clayson, President, International Fiscal Association - Worldwide (Video Recording)
10.00 – 10.30 Break
Plenary Session:
Multilateral Instrument (MLI) and BEPS
Chairman Porus Kaka, former President, International Fiscal Association-Worldwide: 2012-17
10.30 – 11.00 Parthasarathi Shome, Chairman, International Tax Research and Analysis Foundation, India and Visiting Fellow, London School of Economics
International Taxation: Resilience or Decline of Multilateral Instrument
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11.00 – 11.30 Sam Sim, Executive Board Member, Asia Chapter, TEI, Singapore
Digital disruption to the Global Value Chain and the Future of Transfer Pricing
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11.30 – 12.00 Mindy Herzfeld, Professor, University of Florida, USA
US Tax Reform & BEPS: A Symbiotic Relationship
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12.00 – 12.30 John Peterson, Head of Aggressive Tax Planning Unit, OECD, Paris
OECD/BEPS - Global Developments and Aggressive Tax Planning (An Overview)
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12.30 – 13.00 Ola Ostaszewska, Manager IBFD European Knowledge Group, The Netherlands Book Launch of IBFD Publication of Basic International Taxation - Vol.One (Third Edition) along with some comments on the new Publication.
13.00 – 13.15 Lunch Break
Plenary Session:
Afternoon
Chairman Belema Obuoforibo, Director of Knowledge Centre,International Bureau of Fiscal Documentation, The Netherlands
14.00 – 14.30 Monica Bhatia, Head of Global Forum Secretariat, OECD, Paris
Exchange of Information (including Beneficial Ownership) under Action Thirteen: Some Issues and Comments
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14.30 – 15.00 Ian Young, Ex-Chair, UK Charter Committee, HMRC, UK
A Review of Taxpayers' Charters and Taxpayers' Protection: Comments
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15.00 – 16.30 Milind Kothari, Managing Partner, BDO India LLP, India
Tax Technology-Tax Practice-Transformation & Disruption Panelists: Rahul Kashikar -Rahul Patni - Dev Ramnane - Amit Sarkar - Vinay Sethi (all from India)
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16.30 – 17.00 Belema Obuoforibo , Session Chairman - Concluding Remarks
17.00 – 17.30 Tea Break
Plenary Session:
Late Afternoon (Option A)
Chairman William Morris, Deputy Global Tax Policy Leader with PricewaterhouseCoopers, USA & Chairman, BIAC (Video Recording)
Nishith Desai (Stand-In)
17.30 – 19.30 International Taxation of Digitised Business: Current Scenario Panel Discussion led by Sol Picciotto,UK. Panelists: Robert Danon,Switzerland - Sriram Govind, Vienna WU - Mindy Herzfeld, USA -Akhilesh Ranjan, India - Mike Williams, UK, followed by Chairman's Remarks and comments from the floor.
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Plenary Session:
Late Afternoon (Option B)
Chairman Rodney Lawrence, Global Leader, International Tax Services, KPMG, United States
17.30 – 19.30 Recent Tax Reforms in the United States (2017): their Current Status and their Impact on other major Global Tax Systems
Panel Discussion led by Marc Levey, USA: Panelists: Hitesh D. Gajaria,India - Pragya Saksena, India - Robert Stack, USA - Christopher Xing,China - Lawrence Zlatkin, USA followed by Chairman's Remarks and comments from the floor
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19.30 – 22.00 Networking Dinner

DAY TWO: DECEMBER 7, 2018 (FRIDAY)

Plenary Session:
BEPS in India: Impact on Indian Tax Policy and Objectives
Chairman Dinesh Kanabar, , Founding Partner, Dhruva Advisors LLP, India
09.00 – 09.15 Session Chairman's Introductory Remarks
09.15 – 9.45 Akhilesh Ranjan, Member, Central Board of Direct Taxes and Principal Chief Commissioner of Income Tax (International), India
Recent Developments in International Taxation in India under BEPS
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9.45 – 10.15 Parthasarathi Shome, Chairman, International Tax Research and Analysis Foundation, India and Visiting Fellow: London School of Economics.
International Taxation: The Economic and Legal Interface
10.15 – 10.45 Tea Break
Chairman Parthasarathi Shome, Chairman, ITRAF, India
10.45 –12.30 BEPS and Indian Tax Policy, Practice and Compliance in Future
Panel Discussion led by Dinesh Kanabar Panelists: Ketan Dalal - Gautam Doshi - Hitesh D. Gajaria - Vipul Jhaveri - Milind Kothari - Pranav Sayta - Girish Vanvari (all from India)
12.30 – 13.00 Dr. Bibek Debroy, Chairman, Advisory Council to the Prime Minister, India
Making of New India through Transformation under Modi Government
Book Launch - Author: Dr. Bibek Debroy
13.00 – 1400 Lunch Break
WELCOME TO OECD DIRECTOR AND SPEAKERS
Chairman Professor Roy Rohatgi, Conference Director
14.00 – 15.15 The OECD's Challenges and Contributions to International Taxation with Special reference to BEPS Project. "Klaus Vogel" (Keynote) Speaker: Pascal Saint-Amans. Other Speaker from OECD (Paris) include Monica Bhatia - John Peterson - Jeffrey Van Hove Brief presentations followed by Questions and Vote of Thanks byRajesh Ramloll Mauritius.
Session
Digitised Business: Latest OECD Proposals
Chairman Sol Picciotto, Professor, International Centre for Tax & Development, UK
15.15– 16.30 International Taxation of Digitized Business: Recent OECD Proposals (December 2018).
Discussion in the presence of Pascal Saint-Amans, OECD, led by Sol Picciotto, UK, and followed by Panel Discussion. Panelists: Rasmi Ranjan Das, India - John Peterson, OECD Sam Sim, Singapore - Jeffrey Van Hove, OECD- Mike Williams, UK.
16.30 – 17.00 Tea Break
Session
Treaties and Tax Certainty under MLI (Option A)
Chairman Robert Stack,, Managing Director, Deloitte Tax & International Tax Group, USA
17.00 – 18.15 Post BEPS Treaties and Tax Certainty under Multilateral Instrument: Can Tax Certainty be achieved with a Policy of Abuse Prevention in post BEPS World?
Presentation by Robert Danon, Professor, Lausanne University, Switzerland & Chair, Permanent Scientific Committee, International Fiscal Association followed by Panel Discussion in the presence of Pascal Saint-Amans, OECD led by Rajesh Ramloll, Mauritius. Panelists: Mukesh Butani, India - Belema Obuoforibo, IBFD - John Peterson, OECD - Jeffrey Van Hove, OECD - with final comments by the Chairman and Professor Robert Danon, Lausanne.
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Session
Mergers and Acquisitions (Option A)
Chairman Gautam Doshi, Managing Director, Anil Dhirubhai Ambani Group, India
18.15 – 19.30 Tax Trends in Mergers and Acquisitions.
Presentation by Girish Vanvari,Founder, Transaction Square LLP, India followed by Panel Discussion led by Pranay Bhatia, India. Panelists: Vivek Gupta, India - Bobby Parikh, India - Amrish Shah, India - Himanshu Sinha, India - Jeffrey Van Hove, OECD.
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Session
Judicial Tax Perceptions of the Permanent Establishment (Option B)
Chairman Vijay Mathur, Senior Tax Advisor, PricewaterhouseCoopers, India
17.00 – 19.30 Presentation by Radhakishan Rawal, Partner, Deloitte, Haskins and Sells LLP on Varying Tax Perceptions for determining Permanent Establishment and the Approach of the Judiciary towards them, followed by Panel Discussion led byJairaj Purandare, India. Panelists: Kuntal Dave, India - Akshay Kenkre, India - Mahesh Kumar, Singapore - Ola Ostaszewska, IBFD - PVSS Prasad, India -Simachal Mohanty, India - Kamlesh Varshney, India.
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19.30 – 22.00 Networking Dinner hosted by International Bureau of Fiscal Documentation(IBFD) to celebrate their 80th anniversary since its establishment in 1938.

DAY THREE: DECEMBER 8, 2018 (SATURDAY)

Session
Tax Dispute Resolution (Morning)
Chairman Hon'ble Justice P P Bhatt, President, Income Tax Tribunal, India
09.00 – 10.30 Resolution of Tax Disputes in the post BEPS World - What are the New Legal Measures and Approaches in Domestic and International Laws recommended under BEPS Action 14? A Critical Review. Panel Discussion led by Rajesh Ramloll, Mauritius. Panelists: Rajat Bansal, India - Pramod Kumar, India - Sunil Moti Lala, India - Jeffrey Owens, UK - G S Pannu, India - Himanshu Sinha, India, followed by Chairman's Remarks
10.30 – 11.00 Tea Break
Session
Impact of New Technologies on International Taxation (Option A)
Chairman Clive Baxter, Maersk Group, Head of Tax Governance and Policy, Denmark
11.00 – 13.00 Likely Implications of the New Technologies on future Tax Policy and Administration
(Examples: Artificial Intelligence, Robotics, Analytics, Virtual Reality, Block Chain, etc.) Presentation by Professor Jeffrey Owens, Vienna WU Austria.
Impact on (i) Tax Systems, (ii) Tax Administrations, and (iii) Tax Policies of the Future. Panel Discussion led by Craig West,South Africa. Panelists: Monica Bhatia, OECD - Shikha Mehra, India - Neil Pennington, UK - Sam Sim, Singapore Jon West, USA in the presence of Jeffrey Owens, UK
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Session
Artificial Avoidance of Permanent Establishment Status under Action 7 (Option B)
Chairman Shefali Goradia, Partner, Deloitte Touche Tohmatsu India LLP, India
11.00 – 12.00 (i) Dependent Agent Permanent Establishment under BEPS: Is it a Permanent Establishment Under Action 7 ?
(ii): Does Permanent Establishment as a Tax Concept have a long-term future in model treaties?
Panel Discussion led by Rajesh Simhan, India. Panelists: Bijal Ajinkya, India - Daksha Baxi,India - Amar Mehta, Canada - Jeffrey Van Hove, OECD
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Session
Transfer Pricing Developments (Option B)
Chairman Vijay Iyer, Partner, Ernst & Young LLP, India
12.00 – 13.00 Compare BEPS Actions 8 to 10 on Transfer Pricing with "Arm's Length Method" under Article 9 and with OECD's Revised Guidance on "Transactional Profit Split Method". Will it eventually lead to "formulary apportionment" under the MutualAgreement Procedure?
Panel Discussion led by T P Ostwal, India. Panelists: Rahul Mitra, India - Petruzzi Raffaele, Austria - Sanjeev Sharma, India - Hasnain Shroff, India.
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13.00 – 14.00 Lunch Break
Session
United Nations Model (Option A)
Chairman Nishith Desai, Founder, Nishith Desai Associates, India
14.00 – 16.30 Presentation by Michael Lennard, Chief of International Tax Cooperation and Trade in the Financing for Development Office (FIDO) of the United Nations (Video Recording) on Recent Changes in the UN Model and its Future Role in a BEPS World. Presentation followed by Panel Discussion led by Uday Ved, India. Panelists: Rajat Bansal, India - T P Ostwal, India - Sol Picciotto, UK - Radhakishan Rawal , India - Dhruv Sanghavi, The Netherlands, followed by Chairman's Remarks.
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Session
Taxpayers' Rights and Responsibilities (Option B)
Chairman Shefali Goradia, Partner, Deloitte Touche Tohmatsu India LLP, India
14.00 -16.30 Presentation by Craig West, IBFD & University of Cape Town, South Africa followed by discussion on Brief Review of Taxpayers' Rights and Responsibilities in the Era of Automatic Exchange of Information. Can BEPS lead to Tax Terrorism and should it be avoided? What is Tax Terrorism? Panel Discussion led by Arvind Datar, India. Panelists: Monica Bhatia, OECD - Ashutosh Dikshit, India - Rahul Navin, India - Pranav Sayta ,, India - Edson Uribe , Mexico - Ian Young ,UK, followed by Chairman's Remarks.
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16.30 – 17.00 Tea Break
Session
Digital World: Some new Issues for Taxation (Option A)
Chairman Ola Ostaszewska, Manager, IBFD European Knowledge Group, The Netherlands
17.00 – 17.30 Blockchain Technology: Its Use and Abuse
Presentations by Rita Cunha, UK - Shikha Mehra, India - Neil Pennington, UK
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17.30 –18.00 Future of Blockchain TechnologyPresentation by Jon West, Vice President of Blockchain Engineering for Thomson Reuters, USA
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18.00 – 18.45 Permanent Establishment through Digital Presence: Will it work?
Presentation by Himanshu Parekh, Partner, KPMG in India followed by panel discussion. Panelists: Wasoudeo Balloo, Mauritius -
N Meyyappan,
India.
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Session
Goods and Services Tax (Option B)
Chairman Santosh Dalvi, Partner, KPMG in India
17.00 – 18.45 Goods and Services Tax in India - A Current Update
Panel Discussion led by Santosh Dalvi, India. Panelists: Prashant Bhatnagar - Prashant Deshpande - Ashish Jain - Uday Pimprikar - Amit Sarkar
(all from India)
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18.45 – 19.00 Concluding Remarks and Questions: Monica Bhatia (OECD) -Belema Obuoforibo (IBFD) - Roy Rohatgi (FIT) .
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