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IBFD, Your Portal to Cross-Border Tax ExpertiseIBFD, Your Portal to Cross-Border Tax Expertise
An African Perspective • 4-6 May 2016 • Entebbe • Uganda
International Taxation Conference 2016 First-ever joint conference FIT and IBFDBEPS and Beyond BEPS: A Year Later
1-3 December 2016, ITC Maratha Hotel, Mumbai
IBFD, Your Portal to Cross-Border Tax Expertise
International Taxation Conference 2016
FIT is an educational, charitable trust in India,
established to promote knowledge and understanding
of international tax laws through research, training,
publications and other allied activities. This forms an
ideal match with our own IBFD mission to advance
the dissemination and understanding of information
on cross-border taxation. FIT has presented the
leading annual International Taxation Conference since
1995, making this the 21st year of the event. We are
honoured to partner with them for the first time for this
year’s conference.
The growing BEPS landscape
The 2016 conference theme is BEPS and Beyond
BEPS: A Year Later. We have identified key BEPS
issues for debate, panel discussions and presentations
by experts, who will be represented by a diverse mix
of academia, corporations, IGOs, NGOs, revenue
authorities and tax practice. The conference will
respond to the growing excitement in the international
tax world around the G20 base erosion and profit
shifting project, led by the OECD. This project’s focus
has progressed beyond tax-free “homeless” income by
multinational corporations, and extends to a
holistic review of tax avoidance by a wide range of
tax measures.
Plenary sessions on key topics
Throughout the conference, our expert speakers will
introduce and guide the daily plenary sessions. Porus
Kaka (President of the International Fiscal Association
– Worldwide) will kick off Day One’s session on Action
15 for the development of a multilateral instrument
(MLI) under BEPS. On Day Two, the morning’s session
will be on BEPS and Indian tax policy, practice and
compliance – speakers include Anita Kapur (former
CBDT Chairman); Professor Parthasarathi Shome
(former advisor to previous Finance Minister); and
Akhilesh Ranjan (Chief Commissioner of Income Tax
(International) in India).
Panel discussions of selected issues
In addition to the plenary sessions, both auxiliary and
stand-alone panel discussions will cover a wide range
of BEPS Action Points from twelve selected issues.
As with previous years, we hope and trust that these
discussions by global experts will also increase
understanding of these issues and work towards
furthering their resolution.
Keynote speaker
The keynote “Klaus Vogel” speaker at the conference
is Pascal Saint-Amans, Director of the OECD’s Centre
for Tax Policy in Paris. Mr Saint-Amans has been
head of the BEPS project since its inception at the
OECD and reports regularly to G20 Finance Ministers.
The full programme, including all speakers, is
available on the next two pages and more information
on the event can be found at www.ibfd.org/ITC2016.
We look forward to your participation at our joint
International Taxation Conference 2016!
Former Honorary President:
Professor Klaus Vogel
Conference Director:
Professor Roy Rohatgi
Advisory Committee:
Mukesh Butani, Nishith Desai,
Gautam Doshi, Shanker Iyer,
Dinesh Kanabar, Michael
Lang, T.P. Ostwal, Belema
Obuoforibo, Jairaj Purandare,
Pasquale Pistone, Rajesh
Ramloll, Pranav Sayta, Rohan
Shah, Kiran Umrootkar,
Victor van Kommer, Caroline
Silberztein
We are delighted to partner with the Foundation for International Taxation (FIT) for our first-ever joint International Taxation Conference.
Why attend?
The conference’s intensive
three-day programme will
greatly enrich your un-
derstanding of the BEPS
landscape and significantly
strengthen your network.
To register for one of the limited places, visit www.ibfd.org/ITC2016
BEPS and Beyond BEPS: A Year Later
IBFD, Your Portal to Cross-Border Tax Expertise
Day One: 1 December 2016 (Thursday)
08.00 – 20.00 Registration
09.30 – 09.45 Opening Remarks: Conference Director
09.45 – 10.00 Welcome: IBFD
Plenary Session: Multilateral Instrument (MLI) under BEPS
Chairman: Sohrab Dastur, Senior Advocate, India
10.00 – 10.30 Porus Kaka, President - International Fiscal
Association Worldwide Special Address
10.30 – 11.00 Michael Williams, Director, Business and
International Tax, UK Treasury Chairman, OECD-G20 Working
Group on Multilateral Instrument (Action 15) Development
of Minimum Standards under BEPS Action Plans and their
Enforcement under International and Domestic Tax Laws with
Multilateral Instrument
11.00 – 11.30 Daniel Erasmus, International Tax Attorney,
South Africa
Legal Status of Multilateral Instrument (including BEPS
Reports and Recommendations) for Global Tax Compliance
and Enforcement under International and Domestic Law
11.30 – 12.00 Jesse Eggert, Senior Advisor, BEPS Project,
OECD, Paris
Multilateral Instrument (Action 15): What are its Benefits and
Challenges? Its Impact on Global Tax System of the Future
and Compliance with current and future International Tax
Systems
12.00 – 12.30 Jeffrey Owens, Professor & Director of the
Global Tax Policy Center, WU Austria (former Director, OECD
Paris and FIT Conference Keynote Speaker 2015) (Confirmed)
Moving from BEPS to a Broader Tax Policy Agenda
12.30 – 13.00 Session Chairman’s Remarks and Questions
and Comments from the Floor
13.00 – 14.00 Lunch
Plenary Session: Afternoon
Chairman: Belema Obuoforibo, Director of Knowledge
Centre, IBFD, The Netherlands
14.00 – 14.30 Monica Bhatia, Head of Global Forum
Secretariat, OECD, Paris
Full Transparency and Automatic Exchange of Information
(Examples: CRS & CbyCR) - Will they suffice to counter Tax
Avoidance?
14.30 – 15.00 Geoff Cook, Chief Executive, Jersey Financial
Centre, Jersey (Confirmed)
Role of International Financial Centres under BEPS
15.00 – 15.30 David Spencer, International Tax Lawyer
and former Senior Advisor of Tax Justice Network, USA
(Confirmed)
BEPS and its Impact on the United States Tax System and its
New Model Treaty
15.30 – 16.00 Paolo Valerio Barbantini, Senior Advisor -
Developing Countries Engagement Centre. OECD, Paris
Role of Developing Countries in G20 BEPS Project and its Impact
16.00 – 16.30 Discussion and Questions
16.30 – 17.00 Tea Break
Plenary Session: Late Afternoon (Option A)
Chairman: Rajesh Ramloll, Deputy Solicitor General, Mauritius
17.00 – 19.00 What are the key challenges in the drafting and
implementation of a single Multilateral Instrument for over
100 countries to comply with BEPS Recommendations?
(Examples: What is the status of BEPS Reports in
international law and domestic law? How can Courts
in different countries be bound to an agreement that
gives them economic substance without domestic legal
substance?)
Panel Discussion led by Michael Williams, UK.
Panelists: Mukesh Butani, India - Daniel Erasmus, South
Africa - Jesse Eggert, OECD - Belema Obuoforibo, (IBFD)
- Jeffrey Owens, UK - Parthasarathi Shome, India
Plenary Session: Late Afternoon (Option B)
Chairman: S K Sahai, Member, Central Board of Direct
Taxes, India
17.00 – 19.00 What is the likely Impact of BEPS on
Developing Countries to-date and in future? Has BEPS
Changed the Allocation of Taxing Rights under OECD
Model Treaties in their favour? Does it also give effect to
Economic Substance over Form?
Panel Discussion led by Jairaj Purandare - India.
Panelists: Paolo Barbantini, OECD - Shefali Goradia, India
- K R Girish, India - Vijay Mathur, India - Sol Picciotto,
UK - Akhilesh Ranjan, India - Shreya Rao, India - David
Spencer, USA
19.00 – 22.00 Networking Dinner
Day Two: December 2016 (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 – 09.45 Anita Kapur, former Chairman of Central
Board of Direct Taxes
Impact of Indian Tax Policies and Practices on BEPS (and
vice versa)
09.45 – 10.15 Akhilesh Ranjan, Chief Commissioner of
Income Tax (International), Government of India
BEPS Recommendations and Compliance by India Current
Status and Future Plans
10.15 – 10.45 Parthasarathi Shome, Director, Indian Tax
Research & Analysis Foundation, India
Recent Developments in Indian Tax Laws, Policy and
Practices under BEPS and their Implementation Issues
10.45 – 11.00 Break
11.00 – 13.00 BEPS and Indian Tax Policy, Practice and
Compliance
Panel Discussion chaired by Ms Rani Singh Nair,
Member, CBDT, India and/or Sushil Chandra, Chairman
Designate, CBDT and led by Dinesh Kanabar.
Panelists: Rajat Bansal - Bobby Parikh - Vipul Jhaveri -
Sudhir Kapadia - Gautam Mehra - Rohan Shah - Pragya
Saksena - Girish Vanvari (all from India)
13.00 – 14.00 Lunch
Session: Global Impact of BEPS and Its Future (Option A)
Chairman: Nishith Desai, Founder, Nishith Desai
Associates, India
14.00 – 16.00 How have Multinational Enterprises and
Countries addressed the G20-OECD Recommendations
under BEPS in (a) North America (b) Europe (c) Asia (d)
Africa (e) Rest of the World?
Panel Discussion led by Marc Levey, USA.
Panelists: Paolo Barbantini, OECD - Abhishek Chawla, Far
East - Gokul Chaudhri, India -Ashutosh Dikshit, India - Imke
Gerdes, Austria - Annet Oguttu, South Africa - Andrew
Owen, USA
16.00 – 16.30 Discussion and Questions followed by
Chairman’s Remarks
Session: Tax and Treaty Compliance under BEPS (Option B)
Chairman: Vipul Jhaveri, Head of Tax, Deloitte, Haskins &
Sells, India
14.00 – 15.00 Does Permanent Establishment Concept
have a role in the BEPS Regime of today and in future? Are
the present Recommendations under Action 7 adequate to
counter Abuses arising from BEPS today?
Panel Discussion led by Shefali Goradia, India.
Panelists: Bijal Ajinkya, India - Rahul Garg, India - Vladirim
Gidirim, Russia -Jan de Goede (IBFD) - Johann Hattingh,
(IBFD) - Milind Kothari, India - Uday Ved, India
Chairman: Girish Vanvari, Head of Tax, KPMG, India
15.00 – 16.00 BEPS and Indo-Mauritius Treaty Protocol
2016 and similar Indian and foreign Treaties
Panel Discussion led by Daksha Baxi, India.
Panelists: W. Balloo, Mauritius - Pranay Bhatia, India -
Gary Gowrea, Mauritius - Shanker Iyer, Singapore - Sushil
Khushiram, Mauritius - Rahul Navin, India - Ramakrishna
Sithanen, Mauritius
16.00 – 16.30 Discussion and Questions
16.30 – 17.00 Tea Break
Session: Late Afternoon (Option A)
Chairman: Gautam Mehra, Head of Tax,
PricewaterhouseCoopers, India
17.00 – 19.00 Tax Evasion, Money Laundering & Other
forms of Black Money and their Impact (Action 12 -14)
Panel Discussion led by Jeffrey Owens, UK.
Panelists: Kuntal Dave, India - Gautam Doshi, India -Jan
de Goede (IBFD) - Michael Kobetsky, Australia - Mahesh
Kumar, Singapore - T P Ostwal, India - Pragya Saksena,
India
Session: Late Afternoon (Option B)
Chairman: Satya Poddar, Head of Indirect Taxes, Ernst &
Young, India
17.00 – 19.00 Proposed Goods and Services Tax in India
Recent Developments
Panel Discussion led by Sachin Menon, KPMG, India.
Panelists: Prashant Deshpande, Rajeev Dimri, Bhavna
Doshi, Sujit Ghosh, Rohan Shah (all from India) plus 3
expert Speakers from Indian Revenue and Government
19.00 – 22.00 Networking Dinner
To register for one of the limited places, visit www.ibfd.org/ITC2016
Conference Programme
IBFD, Your Portal to Cross-Border Tax Expertise www.ibfd.orgIBFD, Your Portal to Cross-Border Tax Expertise
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Day Three: 3 December 2016 (Saturday)
Chairman & Guest of Honour: R V Easwar, Former Judge, High
Court of Delhi, Ex-Officiating President, ITAT
09.00 – 09.15 Welcome and Introduction : R V Easwar by
Mukesh Butani, Session Chairman and Pranav Sayta, National
Partner, Ernst & Young, India
09.15 – 10.00 Tax Disputes under Domestic and International
Laws involving MAP and/or Multilateral Instrument under BEPS
(Actions 14 & 15) Coordinated and led by Mukesh Butani, India.
Panelists: Carol Dunahoo, USA - Arvind Datar, India, Jesse Eggert,
OECD - Jeffrey Owens, UK - Mohan Parasaran, India - Rajesh
Ramloll, Mauritius -Ajay Vohra, India - Michael Williams, UK.
10.00 – 10.20 Special Speaker : R V Easwar (Introduction by
Pranav Sayta)
10.20 – 10.30 Discussion and Vote of Thanks by Pranav Sayta,
National Partner, Ernst & Young, India
10.30 – 11.00 Break
Session: Tax and Treaty Conflicts (Option A)
Chairman: Pranav Sayta, National Partner, Ernst & Young, India
11.00 – 13.00 Future of Digital Economy under BEPS Action 1
Presentation on”Equalization Levy” on Digital Transactions in
Cross-Border E-Commerce (enacted in India as from April 1,
2016) by Rashmin Sanghvi, Partner, Rashmin Sanghvi Associates,
India followed by Discussion led by Pranav Sayta, India.
Panelists: Daksha Baxi, India - Padamchand Kincha, India -
Rakesh Nangia, India - Rashmin Sanghvi, India - Mansi Seth,
USA - Rohinton Sidhwa, India –Vinay Singh, India
Session: Transfer Pricing Developments (Option B)
Chairman: Rohan Shah, Managing Partner, Economic Laws
Practice, India
11.00 – 13.00 Transfer Pricing under BEPS Actions 8-10
Panel Discussion led by Anis Chakravarty, India.
Panelists: Vijay Iyer, India - Michael Kobetsky, Australia - Marc
Levey, USA - Amar Mehta, Canada - Sol Picciotto, UK - Sanjeev
Sharma, India - G C Srivastava, India -Miller Williams, USA
13.00 – 14.00 Lunch
14.00 – 15.00 KEYNOTE SPEAKER
Chairman: Professor Roy Rohatgi, Conference Director
“Klaus Vogel” Speaker: Pascal Saint-Amans, Director - OECD
Paris followed by Questions (Confirmed)
Vote of Thanks by Rajesh Ramloll, Mauritius
BEPS and Beyond BEPS: A Year Later
Session: Minimum Standards under Action 5 & 6 (Option A)
Chairman: Sushil Khushiram, former Minister of Financial
Services, Mauritius Impact and Implications of Harmful Tax
Competition and Treaty Shopping under BEPS
15.00 – 16.30 Panel Discussion led by Ashutosh Dikshit, India.
Panelists: Aladesawi Adeyemi, South Africa - Geoff Cook,
Jersey - Rahul Garg, India - Gary Gowrea,
Mauritius - Ridha Hamzaoui (IBFD) - Bela
Sheth Mao, India - Rajesh Simhan, India
Session: Transfer Pricing Developments (Option B)
Chairman: Gautam Doshi, Group Managing Director,
Reliance ADAG India
15.00 – 16.30 Exchange of Tax Information with Transfer
Pricing Documentation under BEPS (Action 13)
Session coordinated by Caroline Silberztein, France and
led by Sanjiv Malhotra, India.
Panelists: Monique van Herksen, The Netherlands -
Bawono Kristiaji, Indonesia - Sunil Lala, India - Rahul K
Mitra India - Himanshu Sinha, India
16.30 – 17.00 Break
Joint Final Session: BEPS Project Will it succeed? (Panel
Discussion)
Chairman: Jeffrey Owens, UK
17.00 – 18.55 (a) Will BEPS Project help to counter Unfair
Tax Competition?
(b) Is Tax Planning Dead?
Panel Discussion led by T P Ostwal, India.
Panelists: Arvind Datar, India - Nishith Desai, India -
Gautam Doshi, India - Vipul Jhaveri, India - Sudhir Kapadia,
India - Bobby Parikh, India - Michael Williams, UK - in
presence of Pascal Saint-Amans, Paris
18.55 – 19.00 Professor Roy Rohatgi, Conference Director -
Concluding Remarks
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