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.

Conference Programme 2008

Friday, December 5, 2008
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
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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
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11.45 – 12.15 Garry Stone, Global and US Leader of the Transfer Pricing Group, PricewaterhouseCoopers, United States –
Transfer Pricing for Intercompany Services
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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
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12.45 – 13.00 Discussion & Questions and 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
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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
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15.00 – 15.30 Prakash Chandra, Director General (Foreign Tax Division) Government of India (confirmed)
Transfer Pricing Compliance – A Revenue Perspective
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15.30 – 16.00 David Sutherland, Managing Director, Morgan Stanley Asia, Hong Kong (confirmed)
Some Transfer Pricing Compliance Issues in Asia – A Taxpayers’ Perspective
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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 Presentations by the Netherlands Foreign Investment Agency
Topic – Tax issues in Doing Business with the NetherlandsClick Here to view the Presentation

20.00 – 21.00 Presentations by the Flanders Investment and Trade Agency, Belgium and AAMILLtd.
Topic – Tax Issues in Doing Business in BelgiumClick Here to view the Presentation

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
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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
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11.30 – 12.00 Shikha Gupta, Head- India, General Electric Corporation, India –
Recent Developments in Global Transfer Pricing Documentation
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12.00 – 12.30 Shanto Ghosh, Director and Principal Economist, Deloittes, India –
Cost Contribution Agreements in Transfer Pricing – Internatioanl Best Practices
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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
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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
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15.00 – 15.30 Heinz-Klaus Kroppen, Europe, Middle East and Africa Transfer Pricing Leader, Deloitte, Germany –
Issue of Locational Savings in Transfer Pricing
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15.30 – 16.00 Discussions & Questions
16.00 – 16.30 Tea
16.30 – 17.75 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