International Fiscal Association

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1 CONFERENCE ON INTERNATIONAL TAXATION EMERGING & CONTEMPORARY GLOBAL TAX TRENDS Friday, December 18, 2015 Taj Deccan Banjara Hills, Hyderabad

2 (IFA) is a premier international body headquartered in the Netherlands, engaged in shaping the evolution of tax and fiscal policies across the globe. IFA carries on research in areas of fiscal economics, tax administration and tax policies. About the Conference : The arena of International Taxation has consistently evolved over the years and is set to embark upon a new global platform aimed at synchronizing and delivering equity. Organization of Economic Co-operation and Development [OECD], at the behest of G- 20,issued reports on 15 action plans on October 5,2015,for tackling Base Erosion and Profit Shifting (BEPS). These are likely to be implemented by major economies (including BRICS) by suitably amending their respective domestic tax laws. These BEPS reports aim at curbing the exploitation of the gaps in tax rules of countries that artificially shift profits to either low or no-tax locations. With these rapid developments in the international arena, domestic tax laws are on the verge of incorporating numerous amendments to implement the BEPS guidelines. Information sharing, transparency and substance over form are the buzz words in the tax world today. India, an active participant in the BEPS project, is keen to implement the BEPS guidelines along with GAAR under the domestic law. For multi-national corporations, these developments are no more just a tax subject but could have implications across the business processes. With this background, IFA, Hyderabad sub-chapter has taken initiative of conducting a conference to discuss and critically analyse the global and domestic developments. Eminent personalities from across India have consented to contribute on the above subject. This conference provides an ample opportunity to enrich academic knowledge by understanding the nuances and impacts of the changing regulatory scenarios and the challenges faced both by the industries, tax professionals and the Government.

3 REGISTRATION & BREAKFAST : 8.30 am am. INAUGURATION : 9.15 am am. The conference will be inaugurated by Chief Guest Hon'ble Mr. Justice Challa Kodandaram, High Court of Telangana & AP. TECHNICAL SESSION- I : 9.45 am am INTERNATIONAL TAX DEVELOPMENTS-TRANSFER PRICING, BASE EROSION & PROFIT SHIFTING & PLACE OF EFFECTIVE MANAGEMENT. Speaker : Mr. Sanjay Tolia, Partner, PWC Chairman : Mr. PVSS Prasad, Partner, M/s Prasad & Prasad The transfer pricing developments, emboldened by the BEPS guidance require a threadbare analysis of their nuances, implications and their applicability to all relevant stakeholders. Country by country reporting (CbCR) and alignment of returns with value creations are significant outcome of BEPS initiative advocating transparency and substance parameters across the MNC group entities. Further the Place of Effective Management(POEM) provisions require a significant analysis of the management structure of the overseas subsidiaries. This session will provide a critical insight into the nitty gritty of provisions relating to new transfer price developments, relevant BEPS action plans and POEM. Also the speaker will deliberate upon the risks, opportunities and planning avenue surrounding these path breaking developments. TEA BREAK : am am TECHNICAL SESSION - II : am pm DIGITAL ECONOMY: A NEW ERA OF TAX PLANNING & COMPLIANCE Speaker : Mr. Rashmin Sanghvi, Partner, Rashmin Sanghvi & Associates Information and communication technologies are great enabler of business without boundaries. However, it has posed a significant challenge to the principles of taxation generally associated with territorial based taxation. The greater ability to avoid nexus in market jurisdictions is exacerbated due to the significance of intangible assets in the digital economy and the ability to hold such intangible assets in favorable tax jurisdictions. This session will provide an incisive analysis into the tax related issues associated with Digital Economy. LUNCH : 1.00 pm pm

4 TECHNICAL SESSION - III : 1.45 pm pm CASE STUDIES ON TAXATION OF EXPATRIATES Speaker : Mr. Nikhil Bhatia, Partner, PWC An employee is a great asset to a Global MNC and his/her potential and abilities are utilised by the MNC group to the fullest extent without limiting to a particular jurisdiction. However, complex taxation and labour laws pose significant challenges in making it an extremely complex preposition in terms of compliance and cost. The speaker will endeavor to address various facets of complex issues surrounding deputation & dual employment such as permanent establishment, social security, terminal payments etc. TEA BREAK : 3.15 pm pm TECHNICAL SESSION - IV : 3.30 pm pm MERGER & ACQUISITIONS PRACTICAL CASE STUDIES OF M&As INVOLVING INDIAN ENTITIES. Speaker : Mr. Amrish Shah, Partner, EY Mergers &Acquisitions are the significant propellers of inorganic growth. A successful merger is a pristine wish of any organisation and is like a rare specie. A successful M&A is an outcome of numerous factors such as sharp sighted business considerations, meticulous tax planning strategies, regulatory considerations etc. This session will provide insights into the tax and regulatory challenges of M&As in the post BEPS era. The Speaker will also delve upon the recipe of a successful M&A and the guiding steps to make it successful. TECHNICAL SESSION - V : 5.00 pm pm LATEST DEVELOPMENTS IN GST Speaker : Mr. Sagar Shah, Partner, BDO India LLP Upcoming GST is a significant milestone and most probably a single largest enactment that will change entirely the indirect tax scenario in India. In synchronization with Make-in-India initiative, it is expected to provide much awaited relief to taxpayers by ensuring seamless credit set off mechanism. This session is dedicated for deliberations on the latest developments in the GST scenario and hence aims at providing a current update on this impactful legislation.

5 DELEGATE FEES : (including service tax) For Members of IFA : Rs. 2,700. For Non-members : Rs. 3,300 Early Bird discount for non-members Rs.500 if payment is received before 4th December, Group Bookings : Group Booking above 3 members (non-ifa members) from an organization : Rs. 2,700 per person. Mode of Payment of delegate Fees : (Online Payment) :, Hyderabad subchapter, HDFC Bank(Himayatnagar). Account No : , IFSC Code HDFC Cheque Payment : Cheque should be drawn in favour of ', Hyderabad subchapter' along with the registration form to Mr. Pankaj Jain, Ernst & Young LLP, Oval Office 18, ilabs Center Hitech City, Madhapur, Hyderabad Phone : Office Bearers : Simachal Mohanty Chairman simachalm@drreddys.com B. Vijayaprasad Vice Chairman bvpcahyd@hotmail.com Pankaj Jain Treasurer pankaj.jain@in.ey.com Online Media Partner IFA booklet containing topics on latest trends of Global Trends & Transfer Pricing is available for all the participants

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