joint conference between...ketan dalal - gautam doshi - hitesh d. gajaria - sunil gupta - vipul...

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Please Turn Over OUR SESSION CHAIRMEN DECEMBER 5-7, 2019, ITC MARATHA HOTEL, MUMBAI INTERNATIONAL TAXATION CONFERENCE 2019 (Provisional : As at October 10, 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) Conference Promotion by ® 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 : [email protected] OR [email protected] 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 TAXATION Trustees: Professor Roy Rohatgi, Kiran Umrootkar, T P Ostwal, Sachin Menon, Sunil Moti Lala, Mukesh Butani Registered Office : 622 Maker Chambers V, 221 Nariman Point, Mumbai - 400 021 India JOINT CONFERENCE BETWEEN FOUNDATION 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; Sol Picciotto, Lancaster University, United Kingdom; Dinesh Kanabar, Dhruva Advisors LLP, India; Jeffrey Owens, Vienna WU, Austria; Nishith Desai, Nishith Desai Associates, India; Mukesh Butani, Trustee, FIT, India; Vijay Mathur, PwC, India; Rachel Saw Malaysia; Clive Baxter, A P Moller -Maersk A/S, Denmark; Ola Ostazewska, IBFD, The Netherlands; T P Ostwal, T P Ostwal & Associates LLP, India; , IBFD, BETTER POLICIES FOR BETTER LIVES ® 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 of our conference is ADDRESSING THE GLOBAL TAX CHALLENGES ARISING FROM DIGITALISATION. Our keynote topic remains AN OVERVIEW OF AND LIKELY NEW ISSUES UNDER THE OECD AGENDA ON DIGITAL ECONOMY (ACTION ONE). 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 the G20 Finance Ministers on its progress. He plans to submit their draft proposals on Taxation of Digital Economy to G20 Committee for their review in November this year. Our December Conference is perfectly timed for the announcement of their recommendation on the subject. We plan to invite several global experts from his OECD team in Paris and around the world as speakers to support him. Our other eminent speakers this year 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. We look forward to your participation at our 24th Annual Conference this year. GLOBAL TAX REFORM: AN IMPOSSIBLE DREAM? KEYNOTE SPEAKER - PASCAL SAINT-AMANS, OECD, PARIS OUR SUPPORTERS IN 2018 GOLD PLATINUM PATRON ASSOCIATE SILVER taxnotes ® M & J Services -The Eclectic Law Bookstore-

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Please Turn Over

OUR SESSION CHAIRMEN

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

INTERNATIONAL TAXATION CONFERENCE 2019

(Provisional : As at October 10, 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)

Conference Promotion by

®

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 : [email protected] OR [email protected]

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 Moti Lala, Mukesh Butani

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

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; Sol Picciotto, Lancaster University, United Kingdom;

Dinesh Kanabar, Dhruva Advisors LLP, India; Jeffrey Owens, Vienna WU, Austria; Nishith Desai, Nishith Desai Associates, India;

Mukesh Butani, Trustee, FIT, India; Vijay Mathur, PwC, India; Rachel Saw Malaysia;

Clive Baxter, A P Moller -Maersk A/S, Denmark; Ola Ostazewska, IBFD, The Netherlands; T P Ostwal, T P Ostwal & Associates LLP, India;

, IBFD,

BETTER POLICIES FOR BETTER LIVES®

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 of our conference is ADDRESSING THE GLOBAL TAX CHALLENGES ARISING

FROM DIGITALISATION. Our keynote topic remains AN OVERVIEW OF AND LIKELY NEW ISSUES UNDER THE OECD AGENDA ON

DIGITAL ECONOMY (ACTION ONE).

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 the G20 Finance Ministers on its progress. He plans to submit their draft proposals on Taxation

of Digital Economy to G20 Committee for their review in November this year. Our December Conference is perfectly timed for the announcement of their

recommendation on the subject. We plan to invite several global experts from his OECD team in Paris and around the world as speakers to support him.

Our other eminent speakers this year 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.

We look forward to your participation at our 24th Annual Conference this year.

GLOBAL TAX REFORM: AN IMPOSSIBLE DREAM?KEYNOTE SPEAKER - PASCAL SAINT-AMANS, OECD, PARIS

OUR SUPPORTERS IN 2018

GOLD

PLATINUM

PATRON

ASSOCIATE

SILVER

taxnotes®

M & J Services-The Eclectic Law Bookstore-

DAY ONE : DECEMBER 5, 2019 (THURSDAY)

OFFICIAL OPENING

Plenary Session: The Political Economy Context & The New Approach

Session: The Political Economy Context & The 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

1000-1130 “Klaus Vogel” Speaker: Pascal Saint-Amans*, Director, Centre for Tax Policy and Administration, OECD, Paris

Political Economy Context: An Overview of the New Approach

1130-1300 New Taxing Rights : Pillar I - New Nexus and New Allocation of Taxing Rights

Brief overview of key elements of Pillar - I followed by a Panel Discussion led by Pascal Saint-Amans*, OECD. Panelists: Sophie Chatel, OECD - 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 New Taxing Rights : Pillar II - Minimum Tax based on Proposed Global Anti-Base Erosion Tax: Implementation including Use of Withholding Taxes - Thresholds / Carve-outs - Compatibility with Treaties and other Obligations

Brief overview of Pillar - II by Pascal Saint-Amans*, OECD, followed by a Panel Discussion led by Achim Pross, OECD. Panelists: Emma Barrogard, IBFD - Rasmi Ranjan Das*, India - Robert Goulder*, USA - Annet Wanyana Oguttu, South Africa

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: Sophie Chatel, OECD - Richard Collier, OECD - Jeffrey Owens*, UK - Akhilesh Ranjan*, India

1700-1730 Tea Break

Chairman Sol Picciotto*, Professor, Lancaster University, UK

1730-1930 Concluding Discussion in the presence of Pascal Saint-Amans*, OECD led by Marc Levey, USA. Panelists: Rajat Bansal*, India - Natalia Quinones Cruz, Colombia - Ridha Hamzaoui, IBFD - Grace Perez-Navarro, OECD - Michael Kobetsky, Australia with questions and comments from the speakers and from the floor

1930-2200 Networking Dinner

Chairman Dinesh Kanabar*, Founding Partner, 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 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 - Sunil Gupta - Vipul Jhaveri - Milind Kothari - Pranav Sayta - Pragya Saksena - Girish Vanvari (all from India)

1100-1130 Tea Break

Chairman Jeffrey Owens*, Director of the Global Tax Policy Centre, WU

1130-1300 Tax Reforms in Asia

Presentation by Huey Min, Singapore followed by Panel Discussion led by Jeffrey Owens*, UK. Panelists: Robert Goulder*, USA - Sunil Moti Lala*, India - Grace Perez-Navarro, OECD - Kamlesh Varshney*, India

1300-1400 Lunch Break

Chairman Nishith Desai*, Founder and Managing Partner, Nishith Desai Associates, India

1400-1430 Monica Bhatia, Indian Revenue Service (previously Head of Global Forum Secretariat, OECD, Paris

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 Sam Sim*, Singapore

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

1530-1600 Shikha Mehra*, Professor & Consultant, India

Crypto Currencies: Challenges, Risks and Opportunities

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

Taxing the Digital Economy In India: The Nexus Rule

1630-1700 Rick McDonnell*, Ex Head of the FATF, Paris

Accessing information to Counter Money Laundering & Blackmoney: Getting behind the Corporate Veil and Client/Attorney Privilege

1700-1730 Tea Break

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 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 Rajat Bansal*, India & Rajesh Ramloll*, Mauritius. Panelists: Emma Barrogard, IBFD - Rita Cunha*, UK - 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 and Sells LLP on Attribution of Profits under Article 7 followed by Panel Discussion led by Jairaj Purandare*, India. Panelists: Rasmi Ranjan Das*, India - Kuntal Dave*, India - Akshay Kenkre*, India - Amar Mehta*, Canada - Rahul Navin*, India - PVSS Prasad*, India - Monique van Herksen, The Netherlands

1930-2200 Networking Dinner

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

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

Panel Discussion led by Rajesh Ramloll*, Mauritius. Panelists: Rajat Bansal*, India - Na Li, China - Pramod Kumar, India - Ioanna Mitroyanni, Europe Commission - Asa Mugenyi, Uganda - Jeffrey Owens*, UK - Harm Mark Pit, OECD

1030-1100 Tea Break

Chairman Clive Baxter*, Maersk Group, Head of Tax Governance and Policy, Denmark

1100-1300 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: Monica Bhatia, India - Ranjana Gupta*, New Zealand, Neil Pennington, UK - Sam Sim*, Singapore - Jon West, USA

Chairman Ola Ostazewska, Head, European Knowledge Group, IBFD

1100-1130 To be advised

An Industry Perspective

1130-1200 Rajat Bansal*, Competent Authority, India

A Source Country Perspective

1200-1300 To be advised

1300-1400 Lunch Break

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

1400-1630 Case Study on Transfer Pricing based on BEPS

Panel Discussion led by Rahul Mitra*, India. Panelists: Giammarco Cottani*, Italy - Vijay Iyer, India - Michael Kobetsky, Australia - Petruzzi Raffaele, Austria - Sanjeev Sharma*, India - Mark van Casteren, Singapore

Chairman Ola Ostazewska, Head, European Knowledge Group, IBFD

1400-1630 The Transparency Agenda: Transparency against the Backdrop of Taxpayer Rights and Data Protection

Panel Discussion led by Uday Ved*, India. Panelists: Walter Andreoni, Italy - Julia de Jong, IBFD - Shikha Mehra*, India - Edson Uribe, Mexico - Alessandro Turina, IBFD - Jon West, USA

1630-1700 Tea Break

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

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

Presentation : Topic to be advised

1730-1815 Role of Developing Countries : Future Challenges and Prospects in Allocation of Taxing Rights

Panel Discussion led by Monica Bhatia, India. Panelists: Pranay Bhatia, India - Ernie Lai King, South Africa - Sunil Moti Lala*, India - Seun Adu, Nigeria

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

1700-1815 Panel Discussion led by Rajesh Ramloll*, Mauritius. Panelists: Mukesh Butani*, India - Sunil Gupta, India - Julia de Jong, IBFD - Dinesh Kanabar*, India

1815-1830 Closing Ceremony: Belema Obuoforibo (IBFD) - Roy Rohatgi (FIT)

Session: Recent International Tax Decisions (Option A)

Session: Attribution of Profits - Recent Developments (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: Revisiting the 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: Developing Countries in the Emerging International Tax Order: Challenges and Prospects (Option A)

Session: Tax Administration in the Emerging International Tax Order: Challenges and Prospects (Option B)

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

01.0

9.2

019

Provisional as at September 01, 2019 * Confirmed as at September 01, 2019

DAY ONE : DECEMBER 5, 2019 (THURSDAY)

OFFICIAL OPENING

Plenary Session: The Political Economy Context & The New Approach

Session: The Political Economy Context & The 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

1000-1130 “Klaus Vogel” Speaker: Pascal Saint-Amans*, Director, Centre for Tax Policy and Administration, OECD, Paris

Political Economy Context: An Overview of the New Approach

1130-1300 New Taxing Rights : Pillar I - New Nexus and New Allocation of Taxing Rights

Overview of key elements of Pillar I by Pascal Saint-Amans*, OECD followed by a Panel Discussion led by Achim Pross, 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 New Taxing Rights : Pillar II - Minimum Tax based on Proposed Global Anti-Base Erosion Tax: Implementation including Use of Withholding Taxes - Thresholds / Carve-outs - Compatibility with Treaties and other Obligations

Overview of key elements of Pillar - II by Pascal Saint-Amans*, OECD, followed by a Panel Discussion led by Achim Pross, OECD. Panelists: Emma Barrogard*, IBFD - Rasmi Ranjan Das*, India - Robert Goulder*, USA - Annet Wanyana Oguttu*, South Africa

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 - Sol Picciotto*, UK - Akhilesh Ranjan*, India

1700-1730 Tea Break

Chairman Sol Picciotto*, Professor, Lancaster University, UK

1730-1930 Concluding Discussion in the presence of Pascal Saint-Amans*, OECD led by Rajat Bansal*, India. Panelists: Vidushi Gupta*, India - Ridha Hamzaoui*, IBFD - Grace Perez-Navarro*, OECD - Michael Kobetsky*, Australia with questions and comments from the speakers and from the floor

1930-2200 Networking Dinner

Chairman Dinesh Kanabar*, Founding Partner, 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 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* - Vipul Jhaveri - Milind Kothari* - Pranav Sayta* - Girish Vanvari* (all from India)

1100-1130 Tea Break

Chairman Jeffrey Owens*, Director of the Global Tax Policy Centre, WU

1130-1300 Tax Reforms in Asia

Presentation by To be advised followed by Panel Discussion led by Jeffrey Owens*, UK. Panelists: Robert Goulder*, USA - Sunil Moti Lala*, India - Grace Perez-Navarro*, OECD - Kamlesh Varshney, India

1300-1400 Lunch Break

Chairman Nishith Desai*, Founder and Managing Partner, Nishith Desai Associates, India

1400-1430 Monica Bhatia, Indian Revenue Service (previously Head of Global Forum Secretariat, OECD, Paris)

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 Sam Sim*, Singapore

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

1530-1600 Shikha Mehra*, Professor & Consultant, India

Crypto Currencies: Challenges, Risks and Opportunities

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

Taxing the Digital Economy In India: The Nexus Rule

Research Fellow, SMU Center for Artificial Intelligence,

1630-1700 Rick McDonnell*, Ex Head of the FATF, Paris

Accessing information to Counter Money Laundering & Blackmoney: Getting behind the Corporate Veil and Client/Attorney Privilege

1700-1730 Tea Break

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 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 Rajat Bansal*, India & Rajesh Ramloll*, Mauritius. Panelists: Emma Barrogard*, IBFD - Rita Cunha*, UK - 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 and Sells LLP on Attribution of Profits under Article 7 followed by Panel Discussion led by Jairaj Purandare*, India. Panelists: Rasmi Ranjan Das*, India - Kuntal Dave*, India - Akshay Kenkre*, India - Amar Mehta*, Canada - Rahul Navin*, India - PVSS Prasad*, India

1930-2200 Networking Dinner

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

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

Panel Discussion led by Rajesh Ramloll*, Mauritius. Panelists: Rajat Bansal*, India - Pramod Kumar*, India - Jeffrey Owens*, UK

1030-1100 Tea Break

Chairman Clive Baxter*, Maersk Group, Head of Tax Governance and Policy, Denmark

1100-1300 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: Monica Bhatia, India - Ranjana Gupta*, New Zealand, Neil Pennington, UK - Sam Sim*, Singapore

Chairman Ola Ostazewska*, Head, European Knowledge Group, IBFD

1100-1130 To be advised

An Industry Perspective of the New Taxing Rights

1130-1200 Rajat Bansal*, Competent Authority, India

A Source Country Perspective of OECD Proposals

1200-1300 To be advised

1300-1400 Lunch Break

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

1400-1630 Case Study on Transfer Pricing based on BEPS

Panel Discussion led by Rahul Mitra*, India. Panelists: Giammarco Cottani*, Italy - Vijay Iyer*, India - Michael Kobetsky*, Australia - Petruzzi Raffaele*, Austria - Sanjeev Sharma*, India - Mark van Casteren*,

Chairman Ola Ostazewska*, Head, European Knowledge Group, IBFD

1400-1630 The Transparency Agenda: Transparency against the Backdrop of Taxpayer Rights and Data Protection

Panel Discussion led by Uday Ved*, India. Panelists: Walter Andreoni*, Italy - Julia de Jong*, IBFD - Shikha Mehra*, India - Alessandro Turina*, IBFD

1630-1700 Tea Break

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

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?

1730-1815 Role of Developing Countries in Global Taxation: Impact on Allocation of Taxing Rights of Developing Countries on Proposed OECD Changes

Panel Discussion led by Monica Bhatia, India. Panelists: Pranay Bhatia*, India - Ernie Lai King, South Africa - Sunil Moti Lala*, India -Mustapha Ndajiwo, Nigeria

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

1700-1815 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 - Dinesh Kanabar*, India

1815-1830 Closing Ceremony: Belema Obuoforibo (IBFD) - Roy Rohatgi (FIT)

Session: Recent International Tax Decisions (Option A)

Session: Attribution of Profits - Recent Developments (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: Revisiting the 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: Developing Countries in the Emerging International Tax Order: Challenges and Prospects (Option A)

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

The Netherlands

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

01.0

9.2

019

Provisional as at October 10, 2019 * Confirmed as at October 10, 2019