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OUR SESSION CHAIRMEN

DECEMBER 5-7, 2019, ITC MARATHA HOTEL, MUMBAI

INTERNATIONAL TAXATION CONFERENCE 2019

(As at December 13, 2019)

Former Honorary President: Professor Klaus Vogel Conference Directors: Professor Roy Rohatgi (FIT) &

Belema Obuoforibo (IBFD)

Advisory Committee: Mukesh Butani (India) Nishith Desai (India) Gautam Doshi (India)

Hitesh D. Gajaria (India) Sorrel Hidding (IBFD) Dinesh Kanabar (India)

Milind Kothari (India) Sunil Moti Lala (India) T P Ostwal (India)

Pasquale Pistone (IBFD) Jairaj Purandare (India) Rajesh Ramloll (Mauritius)

Kiran Umrootkar (India) Victor van Kommer (IBFD) Uday Ved (India)

Robert Danon (Switzerland)

Shanker Iyer (Singapore)

Jeffrey Owens (Vienna)

Sol Picciotto (UK)

Pascal Saint-Amans (OECD)

In co-operation with

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 / 60 / 61 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, Dr. (C.A.) Sunil Moti Lala, Mukesh Butani

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

JOINT CONFERENCE BETWEENFOUNDATION FOR INTERNATIONAL TAXATION, MUMBAI

&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; Sol Picciotto, Lancaster University, United Kingdom;

Dinesh Kanabar, Dhruva Advisors LLP, India; Nishith Desai, Nishith Desai Associates, India; Mukesh Butani, Trustee, FIT, India;

Vijay Mathur, PwC, India; Clive Baxter, A P Moller -Maersk A/S, Denmark; Ola Ostaszewska, IBFD, The Netherlands;

T P Ostwal, T P Ostwal & Associates LLP, India; Rachel Saw Malaysia; , IBFD,

Our 24th Annual Conference in 2019 is making a major shift in our focus from Base Erosion and Profit Shifting (BEPS) to a wider topic dealing with Use of

Computers and Digitalisation of the Global Economy. The theme for 2019 conference is "GLOBAL TAX REFORM: AN AMBITIOUS DREAM?" Our

keynote topic remains NEW TAXING RIGHTS : PILLAR I - NEW NEXUS AND NEW ALLOCATION OF TAXING RIGHTS.

As in previous year, our first speaker is Murray Clayson, the Current Worldwide President of the International Fiscal Association, with Porus Kaka, our

Past President, as the Session Chairman. Our Keynote Speaker in this session is Pascal Saint-Amans, Director of the OECD's Center for Tax Policy, based

in Paris. He heads the BEPS Project and reports regularly to a Committee of G20 Finance Ministers on its progress. He plans to submit the latest draft

proposals on Taxation of Digital Economy to G20 Committee for their comments in November this year. Our December Conference is perfectly timed for the

announcement of their recommendation on the subject in early December. We plan to invite several global experts from around the world as speakers to

support him.

Our other eminent speakers this year on Digital Taxation include Robert Danon, Professor at Lausanne University in Switzerland - Mike Williams from

the UK Treasury in the United Kingdom - Sol Picciotto, Emeritus Professor from Lancaster University, United Kingdom - Jeffrey Owens, Professor &

Director, Global Tax Policy Center at Vienna University - Akhilesh Ranjan, Member, Central Board of Direct Taxes, India.

As last year, the conference will be held jointly with IBFD, Amsterdam, and in co-operation with OECD, Paris. IBFD is the sister organization of

International Fiscal Association. It was set up as its publications, research and training arm in 1938. It is the largest institution of its kind in this field.

Foundation for International Taxation is also a charity and today runs one of the leading conferences annually on international taxation in India.

OUR SUPPORTERS IN 2019

GLOBAL TAX REFORM: AN AMBITIOUS DREAM?

''PROPOSED ALLOCATION OF GLOBAL TAXING RIGHTS OVER DIGITAL INCOME UNDER BEPS ACTION ONE (2019)”

KEYNOTE SPEAKER - PASCAL SAINT-AMANS, OECD, PARIS

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DAY ONE : DECEMBER 5, 2019 (THURSDAY)

OFFICIAL OPENING

Plenary Session: Proposed Allocation of Global Taxing Rights Over Digital Income Under BEPS Action One

Session: Political Economy Context & New Approach

Session: New Taxing Rights - Next Steps

DAY TWO : 6 DECEMBER 2019 (FRIDAY)

Plenary Session: Impact of Recent Developments on Indian Tax Policy and Objectives

Plenary Session: (Afternoon)

0800-2000 Registration

0845-0915 Welcome by Joint Conference Directors

Roy Rohatgi, Managing Trustee, Foundation for International Taxation, India

Belema Obuoforibo, Director of Knowledge Centre, IBFD, The Netherlands

0915-0930 Special Address: Murray Clayson, President, International Fiscal Association - Worldwide (Video Recording)

0930-1000 Tea Break

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

1000-1030 “Klaus Vogel” Speaker: Pascal Saint-Amans, Director, Centre for Tax Policy and Administration, OECD, Paris. Stand-in : Grace Perez- Navarro, Deputy Director, Centre for Tax Policy and Administration, OECD, Paris

Political Economy Context: An Overview of the New Approach

1030-1100 Richard Collier, Senior Tax Advisor, OECD, Paris

The Unified Approach

1100-1300 New Taxing Rights : Pillar I - New Nexus and New Allocation of Taxing Rights

Panel Discussion led by Melissa Dejong, OECD. Panelists: Richard Collier, OECD - Guglielmo Maisto, Italy - Akhilesh Ranjan, India - Mike Williams, UK, with concluding remarks from the Session Chairman

1300-1400 Lunch Break

Chairman Belema Obuoforibo, Director of Knowledge Centre, IBFD, The Netherlands

1400-1530 The New Taxing Rights : Pillar II - Minimum Tax based on Proposed Global Anti-Base Erosion Tax: Implementation includes use of Withholding Taxes & Thresholds / Carve-outs - Compatibility with Treaties and other Obligations

Panel Discussion led by Melissa Dejong, OECD. Panelists: Rasmi Ranjan Das, India - Annet Wanyana Oguttu, South Africa - David Stewart, USA

Chairman Sol Picciotto, Professor, Lancaster University, UK

1530-1700 The New Taxing Rights - Nexus and Tax Treaty Implications: Operational Issues

Panel Discussion led by Robert Danon, Switzerland. Panelists: Richard Collier, OECD - Jeffrey Owens, UK - Akhilesh Ranjan, India

1700-1730 Tea Break

Chairman Sol Picciotto, Professor, Lancaster University, UK

1730-1900 Concluding Discussion. Panelists: Rajat Bansal, India - Vidushi Gupta, India - Ridha Hamzaoui, IBFD - Grace Perez-Navarro, OECD - Michael Kobetsky, Australia, with questions and comments from the speakers and from the floor

1900-2200 End of Day's Session followed by Cocktails and Dinner

Chairman Dinesh Kanabar, CEO, Dhruva Advisors LLP, India

0900-0915 Session Chairman's Introductory Remarks

0915-0945 Akhilesh Ranjan, Member, Central Board of Direct Taxes, India

Recent Developments in International and Domestic Taxation in India

0945-1100 Indian Direct Tax Code Update: Recent Developments in International Tax Law and Practice in India

Panel Discussion led by Dinesh Kanabar. Panelists: Daksha Baxi - Ketan Dalal - Gautam Doshi - Hitesh D. Gajaria - Pranav Sayta (all from India)

1100-1130 Tea Break

Chairman Belema Obuoforibo, Director of Knowledge Centre, IBFD, The Netherlands

1130-1300 Tax Reforms in Africa

Presentation by Ferdinand Nji, Cameroon followed by Panel Discussion led by Annet Wanyana Oguttu, South Africa. Panelists: Ridha Hamzaoui, IBFD - Mustapha Ndajiwo, Nigeria - Mohamed Ben Mlik, South Africa

1300-1315 Digital Taxation - A Holistic View

Authors - Rashmin Sanghvi, Naresh Ajwani & Rutvik Sanghvi

1315-1400 Lunch Break

Chairman Dr.(C.A) Sunil Moti Lala, Advocate & Trustee, Foundation for International Taxation, Mumbai

1400-1430 Sanjay Kapadia, Senior Advisor, KNAV, India

Exchange of Information (including on Beneficial Ownership) under Action Thirteen: Some Issues and Comments

1430-1500 Robert Danon, Professor at University of Lausanne, Switzerland

Relevance of Substance in Cross-border Tax Planning

1500-1530 Grace Perez-Navarro, Deputy Director, Centre for Tax Policy and Administration, OECD, Paris

What drives Taxpayer's willingness to pay taxes?

Book Launch :

1530-1600 Shikha Mehra Professor & Consultant, India

Crypto Currencies: Challenges, Risks and Opportunities

1600-1630 Vidushi Gupta, Senior Resident Fellow and Team Leader, Vidhi Centre for Legal Policy, India

Taxing the Digital Economy in India: The Nexus Rule

1630-1700 Sam Sim, Research Fellow, SMU Center for Artificial Intelligence, Singapore

Going the Way of the Polaroid: Death of the OECD MC Article 9(1) Arm's Length Principle

1700-1730 Tea Break

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Session: Recent International Tax Decisions on BEPS & MLI (Option A)

Session: Attribution of Profits in India and Abroad - Recent Developments under Tax Treaties (Option B)

DAY THREE: DECEMBER 7, 2019 (SATURDAY)

Session: Tax Dispute Resolution (Morning)

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

Session: Impact of New Taxing Right: A Critical Evaluation of the OECD Proposals (Option B)

Session: Transfer Pricing Developments (Option A)

Session: The Transparency Agenda : Some Current Issues (Option B)

Session: Tax Administration under the Emerging International Tax Order for Developing Countries: Challenges and Prospects (Option B)

Chairman Mukesh Butani, Trustee, Foundation for International Taxation, India

1730-1930 Post BEPS Treaties and Tax Certainty under Multilateral Instrument: Can Tax Certainty be achieved with a Policy of Tax 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 led by Rajesh Ramloll, Mauritius. Panelists: Bijal Ajinkya, India - Sriram Govind, Vienna - Ridha Hamzaoui, IBFD - Rajesh Simhan, India

Chairman Vijay Mathur, Senior Tax Advisor, PricewaterhouseCoopers, India

1730-1930 Presentation by Radhakishan Rawal, Partner, Deloitte Haskins & Sells LLP on Attribution of Profits under UN Model followed by Panel Discussion led by Jairaj Purandare, India. Panelists: Rasmi Ranjan Das, India - Kuntal Dave, India - Akshay Kenkre, India - Amar Mehta, Canada - PVSS Prasad, India

1930-2200 End of Day's Session followed by Cocktails and Dinner

Chairman Mukesh Butani, Trustee, Foundation for International Taxation, India

0900-1030 Resolution of Tax Disputes in the New International Tax Order

Panel Discussion led by Mukesh Butani, India. Panelists: Rajat Bansal, India - Jeffrey Owens, UK - Rajesh Ramloll, Mauritius

1030-1100 Book Launch: FEMA Compounding Orders - A Comprehensive Analysis

Authors - Hardik Mehta, Harshal Bhuta, Tanvi Vora

1100-1130 Tea Break

Chairman Clive Baxter, Maersk Group, Chief Tax Counsel, Denmark

1130-1330 Likely Implications of the New Technologies on Future Tax Policy and Administration : An Update. Presentation by Professor Jeffrey Owens, Vienna WU, Austria on their Impact on (i) Tax Systems, (ii) Tax Administrations, and (iii) Tax Policies of the Future followed by Panel Discussion led by Shikha Mehra, India. Panelists: Ranjana Gupta, New Zealand, Sam Sim, Singapore

Chairman Ola Ostaszewska, Head, European Knowledge Group, IBFD

1130-1200 Milind Kothari, Managing Partner, BDO India LLP, India

An Industry Perspective of the New Taxing Rights in India

1200-1230 Kuntal Dave, Proprietor, Nanubhai Desai & Co., Mumbai

Impact on Investments in India: Challenges and Opportunities

1230-1300 Dr. (C.A) Sunil Moti Lala, Advocate & Trustee, Foundation for International Taxation, Mumbai

International Tax Precedents in India having Global Significance

1300-1330 Questions and answers & concluding remarks by Session Chairman

1330-1430 Lunch Break

Chairman T P Ostwal, Managing Partner, T P Ostwal & Associates LLP, India

1430-1630 Case Study on Transfer Pricing based on BEPS

Panel Discussion led by Rahul Mitra, India. Panelists: Vijay Iyer, India - Michael Kobetsky, Australia - Sanjeev Sharma, India - Mark van Casteren, The Netherlands

Chairman Ola Ostaszewska, Head, European Knowledge Group, IBFD

1430-1630 The Transparency Agenda: Transparency against the Backdrop of Taxpayer Rights and Data Protection

Panel Discussion led by Rajesh Ramloll, Mauritius. Panelists: Walter Andreoni, Italy - Julia de Jong, IBFD - Alessandro Turina, IBFD

1630-1700 Tea Break

Chairman Rachel Saw, Head - Asia Pacific, IBFD, Malaysia

1700-1730 Annet Wanyana Oguttu, Professor of Tax Law, Pretoria University, South Africa

CbC Reporting: Implementation Challenges for Developing Countries - As the 2020 Inclusive Framework Review Looms - Is Public CbC Reporting the Way to Go?

1730-1830 Reallocation of Taxing Rights under the OECD Proposals: Impact on Developing Countries. Panel Discussion led by Rajesh Ramloll, Mauritius. Panelists: Mukesh Butani, India - Julia de Jong, IBFD - Ameya Kunte - India, Sol Picciotto -UK

1830-1845 Closing Remarks : Belema Obuoforibo (IBFD) - Roy Rohatgi (FIT)

International Taxation Conference - 2019ADDRESSING THE TAX CHALLENGES OF DIGITALIZATION OF THE ECONOMY

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