conference_presentation_2009

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 2009
Thursday, December 3, 2009

PRE-CONFERENCE SESSION
12.00 – 13.00	Lunch for Conference Delegates
13.00 – 15.30	Proposed Direct Tax in India – Briefing and Comments by selected international tax experts in India and abroad.
15.30 – 16.00	Tea
16.00 – 17.30	Sponsored session â€“ Multiconsult Ltd., Mauritius (a member of CIM Group) Topic – Mauritius Perspective – An Update on its Legal & Regulatory Framework *Click Here to view the Presentation*
19.00 – 22.30	Welcome Social Evening â€“ Cocktails & Dinner at the ITC Maratha Hotel, Mumbai
CONFERENCE PROGRAMME – 2009 Friday, December 4, 2009
Day 1
09.00 – 10.00	Registration & Coffee
10.00 – 10.15	Welcome to the Conference Roy Rohatgi (Conference Director)
Session One
INTERNATIONAL TAX DEVELOPMENT
Chairman	Sohrab Dastur, Senior Advocate, India
10.15 – 11.15	“Klaus Vogel” Speaker – Presentation and Questions Arvid Skaar, International Tax Lawyer and Author, Norway Recent Developments in Permanent Establishment and Attribution Rules *Click Here to view the Presentation*
11.15– 11.50	Michael Lang, Professor and Head of the Institute for Austrian & International Tax Law, WU, Austria Beneficial Ownership Concept in Tax Treaties *Click Here to view the Presentation*
11.50– 12.25	Ned Shelton, Director, Sheltons (International Tax Counsel), Denmark Recent Judicial Trends in Tax Treaty Interpretations *Click Here to view the Presentation*
12.25– 12.45	Discussion & Questions
12.45– 13.00	Sessions Chairman’s Remarks
13.00– 14.00	Lunch
Session Two
ISSUES AFFECTING SOURCE BASED TAXATION
Chairman	Dinesh Kanabar, Executive Director and Leader of Tax Practice of PricewaterhouseCoopers(Pvt.) Ltd., India
14.00 – 15.00	Richard Vann, Challis Professor of Law, University of Sydney, Australia Allocation of Taxing Rights to Source Countries under Model Treaties *Click Here to view the Presentation*
15.00 – 15.30	Girish Dave, Director of Foreign Taxation (Mumbai), Government of India, India Indian Tax Positions under the OECD Model Treaty *Click Here to view the Presentation*
15.30 – 16.00	Pinakin Desai, Partner, Ernst & Young Pvt. Ltd., India Impact of Indian Tax Positions on OECD Model – A Professional View *Click Here to view the Presentation*
16.00 – 16.30	Discussion & Questions
16.30 – 17.00	Tea
17.00 – 18.00	Discussion session chaired by Roger Wheeler, former Tax Head â€“ General Motors, and Marcus Desax, President of the International Fiscal Association, The Netherlands *Allocation of Taxing Rights under Model Treaties â€“ Are they equitable?*
Sponsored Session
18.00 – 19.00	Investing in Canada Jointly sponsored by Borden Ladner Gervais LLP & Stikeman Elliott LLP, Canada *Click Here to view the Presentation by* *Elinore Richardson*
19.00 – 22.30	Cocktails & Dinner
CONFERENCE PROGRAMME – 2009 Saturday, December 5, 2009
Day 2
09.00 – 10.30	*Topic – Advance Pricing Agreements & Compliance Issues* A panel discussion led by Roger Wheeler, former Tax Head – General Motors and Mukesh Butani, Partner, BMR & Associates, India in the presence of Craig Sharon, Director of the APA Program at the Internal Revenue Service in the United States and senior members of the Indian Revenue Service
10.30 – 11.00	Coffee
Session Three (Option One)
INTERNATIONAL TAX STRUCTURING FOR INVESTING ABROAD
Chairman	Jairaj Purandare, Senior Executive Director,PricewaterhouseCoopers, (Pvt.) Ltd.India
11.00 – 11.30	Richard Weisman, Principal, Baker & McKenzie, HongKong Investing in the United States *Click Here to view the Presentation*
11.30 – 12.00	Roy Saunders, Managing Partner, International Fiscal Services Ltd., United Kingdom Investing in the European Union *Click Here to view the Presentation*
12.00 – 12.30	Marcus Desax, Partner, Walder Wyss & Partners Ltd., Switzerland Investing in Switzerland *Click Here to view the Presentation*
12.30 – 13.00	Discussion & Questions
13.00 – 14.00	Lunch
Session Four (Option One)
INTERNATIONAL TAX STRUCTURING FOR INVESTING ABROAD
Chairman	Nishith Desai, Founder – Nishith Desai Associates, India
14.00 – 14.30	Lewis Lu, Partner, KPMG, China Investing in the People’s Republic of China *Click Here to view the Presentation*
14.30 – 15.00	Juan Manuel Idrovo, Partner, CaÃ±Ã³n & CaÃ±Ã³n, Colombia Investing in Latin America *Click Here to view the Presentation*
15.00 – 15.30	Shefali Goradia, Partner, BMR & Associates, India Investing from India *Click Here to view the Presentation*
15.30 – 16.00	Pranav Sayta, Partner, Ernst & Young, India Investing in India *Click Here to view the Presentation*
16.00 – 16.30	Discussion & Questions
16.30 – 17.00	Tea
Session Three (Option Two)
TRANSFER PRICING ISSUE
Chairman	Uday Ved, Executive Director and Head of Tax â€“ KPMG, India
11.00 – 11.30	Matthew Frank, Senior Tax Counsel, Transfer Pricing, General Electric Corporation, United States Bilateral v Unilateral Advance Pricing Agreements â€“ Some Issues *Click Here to view the Presentation*
11.30 – 12.00	Shyamal Mukherjee, Head of Transfer Pricing Practice, PricewaterhouseCoopers, (Pvt.)India FAR (Functions, Assets and Risks) Analysis â€“ Significance and Practical Considerations *Click Here to view the Presentation*
12.00 – 12.30	Bob Ackerman, Americas Leader Transfer Pricing, Ernst & Young, United States Transfer Pricing Issues in a Recessionary Economy *Click Here to view the Presentation*
12.30 – 13.00	Discussion & Questions
13.00 – 14.00	Lunch
Session Four (Option Two)
TRANSFER PRICING ISSUE
Chairman	Samir Gandhi, Head of Transfer Pricing, Deloittes,India
14.00 – 14.30	Michael Murphy, Managing Director, Alvarez & Marsal Taxand LLC, United States (Stand-in Speaker: Darpan Mehta, BMR & Associates, India) Business Restructuring â€“ Minimizing Tax Liabilities *Click Here to view the Presentation*
14.30 – 15.00	Robert Green, Partner,Skadden, Arps, Slate, Meagher & Flom LLP, United States Select Transfer Pricing Problems involved in Intercompany Services *Click Here to view the Presentation*
15.00 – 15.30	Alpana Saksena, Director of Incomeâ€“tax (Transfer Pricing), Government of India, Mumbai, India Recent Judicial Decisions and Developments in Transfer Pricing in India *Click Here to view the Presentation*
15.30 – 16.00	Elinore Richardson, Partner, Borden Ladner Gervais LLP, Canada and Al Meghji, Partner, Osler, Hoskin & Harcourt LLP, Canada Transfer Pricing â€“ A Year in Review *Click Here to view the Presentation by* *Elinore Richardson & Al Megji*
16.00 – 16.30	Discussion & Questions
16.30 – 17.00	Coffee Break
Final Session (Joint)
17.00 – 18.00	Question and Answer session with the Transfer Pricing Directorate, Government of India coordinated by Mr V. K. Mangotra, Director of Incomeâ€“tax (Transfer Pricing), Government of India, Mumbai.
18.00 – 18.55	*Topic – Proposed Direct Tax Code in India* A panel discussion with selected conference speakers and delegates chaired by T.P. Ostwal, Partner, T.P. Ostwal & Associates, India, in the presence of Mr S.S.N. Moorthy, Chairman, Central Board of Dorect Taxes, India.. The session was moderated by Govindraj Ethiraj, editor-in-chief of Bloomberg UTV, India for broadcast on their channel.
18.55 – 19.00	Concluding Remarks – Roy Rohatgi
19.00	End of Conference