OUR SESSION CHAIRMEN

DECEMBER 6-8, 2018, ITC MARATHA HOTEL, MUMBAI

INTERNATIONAL TAXATION CONFERENCE 2018

(As at November 30, 2018)

Former Honorary President: Professor Klaus Vogel Conference Director: Professor Roy RohatgiAdvisory Committee: Mukesh Butani (India) Nishith Desai (India) Gautam Doshi (India) Shanker Iyer (Singapore)

Dinesh Kanabar (India) Michael Lang (Austria) Belema Obuoforibo (IBFD) Jeffrey Owens (UK)T P Ostwal (India) Jairaj Purandare (India) Pasquale Pistone (IBFD) Rajesh Ramloll (Mauritius)Pranav Sayta (India) Jan Maarten Slagter (IBFD) Rohan Shah (India) Parthasarathi Shome (India)Kiran Umrootkar (India) Victor van Kommer (IBFD)

In co-operation with

OUR SUPPORTERS IN 2018

Organized by

For more information, please visit our website www.fitindia.org OR contact Ms. Anjali Advani (Co-ordinator, FIT) OR Ms. Sorrel Hidding (Co-ordinator, IBFD)Tel. : 9122 2202 4259/61; Telefax : 9122 2202 4260 OR Tel. : 0031 20 554 0142 E-mail : internationaltax.foundation@gmail.com OR s.hidding@ibfd.org

A copy of this brochure and the registration form can be downloaded from our website www.fitindia.org and registration can be done online

FOUNDATION FOR INTERNATIONAL TAXATIONTrustees: Professor Roy Rohatgi, Kiran Umrootkar, T P Ostwal, Sachin Menon, Sunil M Lala, Mukesh Butani

Registered Office : 622 Maker Chambers V, 221 Nariman Point, Mumbai - 400 021 India

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JOINT CONFERENCE BETWEENFOUNDATION FOR INTERNATIONAL TAXATION, INDIA

&INTERNATIONAL BUREAU OF FISCAL DOCUMENTATION, AMSTERDAM

IN CO-OPERATION WITH THE ORGANIZATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT, PARIS

Porus Kaka, Senior Advocate, India; Belema Obuoforibo, IBFD, The Netherlands; William Morris, PwC, USA and BIAC; Rodney Lawrence, KPMG Global,USA;

Dinesh Kanabar, Dhruva Advisors LLP, India; Parthasarathi Shome, ITRAF, India; Sol Picciotto, ICTD, UK; Robert Stack, Deloitte, USA;

Gautam Doshi, ADAG, India; Vijay Mathur, PwC, India; Hon'ble Justice P P Bhatt, ITAT, India; Clive Baxter, A P Moller - Maersk A/S, Denmark;

Shefali Goradia, Deloitte Touche Tohmatsu India LLP, India; Vijay Iyer, E & Y, India; Nishith Desai, Nishith Desai Associates, India;

Ola Ostaszewska, IBFD, The Netherlands; Santosh Dalvi, KPMG in India

BETTER POLICIES FOR BETTER LIVES®

Our 23rd Annual conference in 2018 continues from our previous conferences on BEPS IN ACTION. MLI was approved after the ratification of its fifth Instrument in March 2018 and became operational on July 1, 2018. It allowed tax treaty changes needed under BEPS recommendations to be made multilaterally by Member States. Our conference again this year is a joint conference with IBFD in Amsterdam. We are grateful for their support. As in previous two years, it is also organized by us in cooperation with OECD, Paris. Pascal Saint-Amans from OECD is again our keynote speaker. He and his team of experts will make presentations and speak about the recent progress of the BEPS project with MLI in Action at our conference.Day One includes several presentations by international tax experts. It concludes with two high level panel discussions on (i) latest OECD recommendations on international taxation of digitized business and (ii) the recent tax reforms in the United States and their global impact. The panelists include several globally renowned speakers such as William Morris (PWC), Rodney Lawrence (KPMG Global) and Robert Stack (Deloitte) from the States, Robert Danon and Mike Williams from Europe and Christopher Xing and Akhilesh Ranjan from Asia. On Day Two, our session on BEPS in India includes a talk on “Recent Developments in International Taxation in India under BEPS” by Akhilesh Ranjan, Member, Central Board of Direct Taxes and Principal Chief Commissioner of Income-tax (International), India. Professor Parthasarathi Shome, an expert on Indian international tax, will chair a high-level panel discussion by tax experts from leading professional firms in India on “BEPS and Indian Tax Policy, Practice and Compliance in the Future”. We have a book launch with presentation by Dr. Bibek Debroy, who is Chairman of the Economic Advisory Council to the Prime Minister of India, Narendra Modi, on his recent book ''Making of New India through Transformation under Modi Government”.Post lunch, there is a special session to welcome the OECD Director and Speakers with a presentation on “OECD's Challenge and Contributions to International Taxation” followed by a session on “Digitized Business: Latest OECD Proposals”. We have also invited Professor Robert Danon from Switzerland to speak on MLI and Tax Certainty in a session chaired by Robert Stack (former Deputy Assistant Secretary at the US Department of Treasury). This is followed by a panel discussion on “Tax Trends in Mergers and Acquisitions” and a high -level panel on current “Judicial Tax Perception of the Permanant Establishment”. The day ends with a special dinner hosted by IBFD to commemorate their 80th anniversary this year.On Day Three, we start with our traditional early morning discussion on “Resolution of Tax Disputes in a post BEPS World”. We have invited Hon'ble Justice P P Bhatt, President, Income Tax Appellate Tribunal, India to chair this Session. G S Pannu, Vice President, Income Tax Appellate Tribunal is invited to be a part of the panel discussion. This is followed by a presentation by Professor Jeffrey Owens on “Likely Implications of the New Technologies on the future Tax Policy and Administration”. This is reviewed in a panel discussion on how these new technologies transform the (i) tax system, (ii) tax administration and (iii) tax policies. The rest of Day Three includes several speakers and panel discussions on topics such as: (i) Recent Developments in the UN Model, (ii) Protection of Taxpayers' Rights and Responsibilities under BEPS, (iii) Can BEPS lead to Tax Terrorism, and (iv) Varying tax definitions of Permanent Establishment in recent Judicial decisions.The conference ends with presentations and panel discussions on the use of modern technology to manage professional tax practices and services and the use of Blockchain technology to assist tax management and compliance. There is also a brief session on the new Goods and Services Tax in India. The three-day event packed programme also includes daily social get-togethers for networking. The above write-up provides a quick overview. The full programme and speaker designations are given overleaf.

BEPS AND BEYOND BEPS: RECENT GLOBAL DEVELOPMENTS POST RATIFICATION OF THE MULTILATERAL INSTRUMENT (MLI)

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DAY ONE : DECEMBER 6, 2018 (THURSDAY)

Plenary Session: Multilateral Instrument (MLI) and BEPS

Plenary Session: Afternoon

Plenary Session: Late Afternoon (Option A)

Plenary Session: Late Afternoon (Option B)

DAY TWO: DECEMBER 7, 2018 (FRIDAY)Plenary Session: BEPS in India: Impact on Indian Tax Policy and Objectives

WELCOME TO OECD DIRECTOR AND SPEAKERS

Session: Digitised Business: Latest OECD Proposals

0800-2000 Registration0845-0915 Opening Remarks: Roy Rohatgi, Conference Director, Foundation for

International Taxation, IndiaBook Launch - Author : Parthasarathi Shome

0915-0945 Welcome: Belema Obuoforibo, Director of Knowledge Centre, International Bureau of Fiscal Documentation, The Netherlands

0945-1000 Special Address: Murray Clayson, President, International Fiscal Association - Worldwide (Video Recording)

1000-1030 BreakBook Launch - Author : Akshay Kenkre

Chairman Chairman Porus Kaka, former President, International Fiscal Association-Worldwide: 2012-17

1030-1100 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

1100-1130 Sam Sim, Executive Board Member, Asia Chapter, TEI, SingaporeDigital Disruption to the Global Value Chain and the Future of Transfer Pricing

1130-1200 Mindy Herzfeld, Professor, University of Florida, USAUS Tax Reform & BEPS: A Symbiotic Relationship

1200-1230 John Peterson, Head of Aggressive Tax Planning Unit, OECD, ParisOECD/BEPS - Global Developments and Aggressive Tax Planning (An Overview)

1230-1300 Ola Ostaszewska, Manager IBFD European Knowledge Group, The Netherlands Book Launch of IBFD Publication of Basic International Taxation - Vol. One (Third Edition) alongwith some comments on the new Publication

1300-1400 Lunch

Chairman Belema Obuoforibo, Director of Knowledge Centre, International Bureau of Fiscal Documentation, The Netherlands

1400-1430 Monica Bhatia, Head of Global Forum Secretariat, OECD, Paris Exchange of Information (including Beneficial Ownership) under Action Thirteen: Some Issues and Comments

1430-1500 Ian Young, Ex-Chair, UK Charter Committee, HMRC, UKA Review of Taxpayers' Charters and Taxpayers' Protection: Comments

1500-1630 Milind Kothari, Managing Partner, BDO India LLP, IndiaUse of Modern Technology to manage Professional Tax Practices and Tax Compliance, and to provide Advisory Services to Clients: their future Impact on the Profession &Tax Administration. Panelists: Rahul Kashikar -Rahul Patni - Amit Sarkar - Vinay Sethi (all from India)

1630-1700 Belema Obuoforibo, Session Chairman - Concluding Remarks1700-1730 Tea Break

Chairman William Morris, Deputy Global Tax Policy Leader with PricewaterhouseCoopers, USA & Chairman, BIAC (Video Recording) Nishith Desai (Stand -In)

1730-1930 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

Chairman Rodney Lawrence, Global Leader, International Tax Services, KPMG Global, USA1730-1930 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

1930-2200 Networking Dinner

Chairman Dinesh Kanabar, Founding Partner, Dhruva Advisors LLP, India0900-0915 Session Chairman's Introductory Remarks0915-0945 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

0945-1015 Parthasarathi Shome, Chairman, International Tax Research and Analysis Foundation, India and Visiting Fellow, London School of EconomicsInternational Taxation: The Economic and Legal Interface

1015-1045 Tea BreakBook Launch - Author : Parthasarathi Shome

Chairman Parthasarathi Shome, Chairman, International Tax Research and Analysis Foundation, India and Visiting Fellow, London School of Economics

1045-1230 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)

1230-1300 Dr. Bibek Debroy, Chairman, Economic Advisory Council to the Prime Minister, IndiaMaking of New India through Transformation under Modi Government

Book Launch - Author : Dr. Bibek Debroy1300-1400 Lunch Break

Chairman Professor Roy Rohatgi, Conference Director1400-1515 The OECD's Challenges and Contributions to International Taxation with

special reference to BEPS Project

“Klaus Vogel” (Keynote) Speaker : Pascal Saint-Amans. Other Speakers from OECD (Paris) include Monica Bhatia - John Peterson - Jeffrey Van Hove. Brief presentations followed by Questions and Vote of Thanks by Rajesh Ramloll, Mauritius

Chairman Sol Picciotto, Professor, International Centre for Tax & Development, UK 1515-1630 International Taxation of Digitized Business: Recent OECD Proposals

(December 2018)

Panel 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

1630-1700 Tea Break

Session: Treaties and Tax Certainty under MLI (Option A)

Session: Mergers and Acquisitions (Option A)

Session: Judicial Tax Perceptions of the Permanent Establishment (Option B)

DAY THREE: DECEMBER 8, 2018 (SATURDAY)Session: Tax Dispute Resolution (Morning)

Session: Impact of New Technologies on International Taxation (Option A)

Session: Artificial Avoidance of Permanent Establishment Status under Action 7 (Option B)

Session: Transfer Pricing Developments (Option B)

Special Session: United Nations Model (Option A)

Session: Taxpayers' Rights and Responsibilities (Option B)

Session: Digital World: Some new Issues for Taxation (Option A)

Session: Goods and Services Tax (Option B)

Chairman Robert Stack, Managing Director, Deloitte Tax & International Tax Group, USA1700-1815 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

Chairman Gautam Doshi, Managing Director, Anil Dhirubhai Ambani Group, India1815-1930 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

Chairman Vijay Mathur, Senior Tax Advisor, PricewaterhouseCoopers, India1700-1930 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 by Jairaj Purandare, India. Panelists: Kuntal Dave, India - Akshay Kenkre, India - Mahesh Kumar, Singapore - Ola Ostaszewska, IBFD - PVSS Prasad, India - Simachal Mohanty, India - Kamlesh Varshney, India

1930-2200 Networking Dinner hosted by International Bureau of Fiscal Documentation (IBFD) to celebrate their 80th anniversary since their establishment in 1938

Chairman Hon'ble Justice P P Bhatt, President, Income Tax Appellate Tribunal, India0900-1030 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

1030-1100 Tea Break

Chairman Clive Baxter, Maersk Group, Head of Tax Governance and Policy, Denmark1100-1300 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 on the 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 Professor Jeffrey Owens, UK

Chairman Shefali Goradia, Partner, Deloitte Touche Tohmatsu India LLP, India1100-1200 (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

Chairman Vijay Iyer, Partner, Ernst & Young LLP, India1200-1300 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 lead to eventually “formulary apportionment” under the Mutual Agreement Procedure? Panel Discussion led by T P Ostwal, India. Panelists: Rahul Mitra, India - Petruzzi Raffaele, Austria - Sanjeev Sharma, India - Hasnain Shroff, India

1300-1400 Lunch Break

Chairman Nishith Desai, Founder & Managing Partner, Nishith Desai Associates, India1400-1630 Presentation (Video Recording) by Michael Lennard, Chief of International Tax

Cooperation and Trade in the Financing for Development Office (FIDO) of the United Nations on Recent Changes in the UN Model and its Future Role in a BEPS World, 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

Chairman Shefali Goradia, Partner, Deloitte Touche Tohmatsu India LLP, India1400-1630 Presentation by Craig West, IBFD & University of Cape Town, South Africa 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? followed by 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

1630-1700 Tea Break

Chairman Ola Ostaszewska, Manager, IBFD European Knowledge Group, The Netherlands1700-1730 Blockchain Technology: Its Use and Abuse

Presentation by Rita Cunha, UK - Shikha Mehra, India - Neil Pennington, UK 1730-1800 Future of Blockchain Technology

Presentation by Jon West, Vice President of Blockchain Engineering for Thomson Reuters USA

1800-1845 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

Chairman Santosh Dalvi, Partner, KPMG in India 1700 - 1845 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)

1845-1900 Concluding Remarks and Questions: Monica Bhatia (OECD) - Belema Obuoforibo (IBFD) - Roy Rohatgi (FIT)

International Taxation Conference - 2018BEPS AND BEYOND BEPS : RECENT GLOBAL DEVELOPMENTS POST RATIFICATION OF MULTILATERAL INSTRUMENT (MLI)