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International Taxation Conference BEPS and beyond BEPS - A year laterFoundation for International Taxation & IBFD, Amsterdam

December 1-3, 2016, ITC Maratha Hotel, Mumbai

Organized by: Foundation for International Taxation in collaboration with IBFD

IBFD, Your Portal to Cross-Border Tax Expertise

International Taxation Conference

Although the initial BEPS suspense (or concern) has

somewhat diminished in the last six months, the

excitement in the international tax world continues to

grow. The project has enlarged its focus beyond base

erosion and profit shifting through tax free “homeless”

income by multinational corporations to a holistic

review of tax avoidance (not just double taxation)

by a wide range of tax measures. These measures

and their causes (and recommended solutions) are

documented under the specific Action Points in their

published Reports. They impact different countries

differently depending on their domestic tax system,

policies and practices, and hence provide a wide

variety. In our conference this year, we have identified

some of them for discussion and debate through both

presentations by experts and by panel discussions

of knowledgeable academics, corporates, revenue

officials, tax practitioners and taxpayers.

The key topics selected for our 2016 conference

in December are as follows:

(i) Multilateral Instrument (MLI) - Action 15:

This last Action Point deals with developing a single

multilateral instrument which can be agreed and

jointly signed by states to amend their tax treaties

in a post BEPS environment, without the need to

amend each and every bilateral treaty. The key

issues in their implementation appear to be: (i) the

asymmetrical application of the MLI to incorporate

the Model Limitation on Benefits (LOB) currently

being drafted by the OECD Committee; (ii) the notion

of developing minimum standards that cannot be

derogated from the MLI, e.g. with respect to the

inclusion of a LOB in tax treaties and its impact on

the right to make reservations under international law,

and (iii) the practical implementation issues needed

to protect the legal rights of taxpayers under their

domestic law. Unless resolved, each country may also

have to amend its bilateral treaties as well, even after

entering into a MLI. So far, we understand nearly 100

countries have committed to develop the MLI, and it

is scheduled to be ready by December 2016.

We have invited three very eminent experts : Pascal

Saint-Amans (Director, OECD Paris), Mike Williams

(current Chairman of the OECD-G20 Ad Hoc Group

on MLI) and Jeffrey Owens (former Director, OECD

Paris) as speakers in our plenary session on Day One.

Pascal is our “Klaus Vogel” speaker (e.g. keynote

speaker) for the Conference this year.

(ii) Automatic Exchange of Tax Information

- Action 13 :

Other key BEPS Report of major significance is Action

13 on Tax Transparency & Full Automatic Exchange

of Cross border Tax Information followed by Country-

by-Country Reporting on tax matters among countries

to limit Base Erosion and Profit Shifting. Action 13 is

expected to be operational soon.

(iii) Digital Economy - Action 1:

Although the G20 and OECD have not reached a

final conclusion yet, their Report recognizes the

right of countries to adopt options available within

their domestic law or bilateral treaties. India has

Former Honorary President:

Professor Klaus Vogel

Conference Director:

Professor Roy Rohatgi

Conference Advisors:

Mukesh Butani, R. K. Chopra,

Nishith Desai, Gautam Doshi,

Dinesh Kanabar, T. P. Ostwal,

Jairaj Purandare, Kiran, Pranav

Sayta, Rohan Shah, Umrootkar,

Arvid Skaar (Norway),

Caroline Silberztein (France),

Rajesh Ramloll (Mauritius),

Shanker Iyer (Singapore),

Michael Lang (Austria)

Our 2015 Jubilee Conference was devoted to give an overview of Base Erosion and Profit Shifting (BEPS) project of G-20 led by the Organization for Cooperation and Development (OECD). It published its final report in October 2015 which was adopted by the G-20 members in mid November. This final report was preceded by detailed research by the OECD on 15 Action Points over three years.

For more information and registration form,

please visit our website: www.fitindia.org

or contact Ms. Anjali Advani

(Coordinator) Tel: 91 22 2202 4259 / 61 Telefax: 91 22 2202 4260 E-mail: internationaltax.

foundation@gmail.com

BEPS and beyond BEPS - A year later

IBFD, Your Portal to Cross-Border Tax Expertise

recently enacted an Equalization Levy on specified

E-Commerce Transactions applicable as from April

2016.

Others topics selected by us for presentation and/or

debate at the Cconference include: (i) Base Erosion

Measures: Actions 2, 3, 4, 5 & 7; (ii) Treaty Abuse

& Anti-avoidance: Action 6; (iii) Transfer Pricing

& Value Creation: Actions 8 - 10; and (iv) BEPS

& Dispute Resolution: Action 14. We have also

provided time during the Conference for a special

session to give an update of the Indian preparations

for the introduction of the Goods and Services Tax in

the country, as well as for a review of the impact of

GAAR and POEM applicable as from April 1, 2017.

Indian government is also very supportive of the

BEPS project and we have invited senior speakers

from the Indian Revenue to give us their views and

speak on their detailed action plans.

As in previous years, we expect around 500

conference delegates from all over the world.

They include international tax experts, academics,

corporates, professionals and Revenue officials. Our

conference provides an excellent opportunity for

networking and marketing as well as learning about

key recent global developments in taxation. The

Welcome Address at our Conference will be given by

Porus Kaka from India; he is the first Indian President

of International Fiscal Association Worldwide.

This is our first joint Conference along with

International Bureau of Fiscal Documentation (IBFD)

a non-profit foundation established in 1938 in The

Netherlands as a small centre staffed by 4 researchers.

The purpose of this bureau was to supply information

concerning (the application of) tax law and to stimulate

the development of tax science. From that day,

IBFD has steadily grown into what it is today: the

world’s foremost authority on cross-border taxation.

IBFD is the sister organization of International Fiscal

Association (IFA).

We look forward to your participation at our 21st

International Taxation Conference 2016.

ITC Maratha Hotel, Mumbai

Trustees:

Professor Roy Rohatgi, Kiran

Umrootkar, T P Ostwal,

Sachin Menon, Nilesh Kapadia

Registered Office:

622 Maker Chambers V,

221 Nariman Point,

Mumbai - 400 021 India

For more information and registration form,

please visit our website: www.fitindia.org

or contact Ms. Anjali Advani

(Coordinator) Tel: 91 22 2202 4259 / 61 Telefax: 91 22 2202 4260 E-mail: internationaltax.

foundation@gmail.com

Organized by: Foundation for International Taxation in collaboration with IBFD

IBFD, Your Portal to Cross-Border Tax Expertise www.ibfd.orgIBFD, Your Portal to Cross-Border Tax Expertise

X Key Challenges in drafting and implementation of

a single Multilateral Instrument

X Legal status of Multilateral Instrument for Global

Tax Compliance and Enforcement

X Has BEPS Changed the Allocation of Taxing

Rights under OECD Model

X Taxation of Digital Economy and the Role of

Markets and Technology

X BEPS and Impact of Indian Tax Policy, Practice

and Compliance

X Transfer Pricing Issues: Will BEPS solve the

Disputes?

X Tax Disputes and their Resolution under BEPS: Is

Arbitration the solution?

X Abuse of Tax Treaty and the New Anti-avoidance

Rules

X Transparency & Exchange of Information?

Will they suffice to curb Tax Avoidance?

X Does PE Concept have a Future? If not, what

changes are needed?

X Allocation of Global Taxing Rights: Would BEPS

avoid today’s disputes on Global Tax Sharing?

X Impact of BEPS on Developed, Emerging, Mid-

shore and Developing Economies and MNC

X Will BEPS Project help counter Unfair Tax

Competition, Tax Evasion and Black Money?

X BEPS and Money Laundering & Other Forms of

Black Money

X What is the Future of BEPS? Will it succeed with

divergent Global Fiscal Policies in today’s world?

Impact of BEPS on Indian Tax and Treaty Policy

and Compliance Etc.

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For more information

and registration form,

please visit our website:

www.fitindia.org

or contact

Ms. Anjali Advani

(Coordinator)

Tel: 91 22 2202 4259 / 61

Telefax: 91 22 2202 4260

E-mail: internationaltax.

foundation@gmail.com

Patron

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Associates

Our supporters in 2015

Provisional list of topics for Panel Discussion at the conference:

In cooperation with

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