Greetings from IFA. The broad themes to be discussed at the Conference are as follows:

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1 Greetings from IFA We are pleased to inform that IFA-India Branch is organizing a 2-Days International Tax Conference, 2018 to be held in New Delhi from 27th & 28th April, 2018 at Hotel TheLalit, New Delhi. Topical issues relating to cross border taxation, including the impact of BEPS report on tax planning and challenges in implementing the same, developments in the area of sharing of information and co-operation between Governments to curb tax evasion, measures taken by countries to tax E-commerce transactions, etc. shall be discussed at the Conference. The broad themes to be discussed at the Conference are as follows: BEPS Action-1, Report on Digital Economy- PE issues and impact on developing countries BEPS Action-15- Multi-lateral Instrument- Global Harmonization and Enforcement Introduction and Enhancement of GAARs in Asia and effect and Consequences for Treaty Shopping/ Treaty abuse - case studies Global Tax Developments - US Base Erosion Anti- Abuse Tax (BEAT) and other relevant provision in the USA tax reform bill, Australian Federal Court decision in the case of Tech Mahindra Limited, Exchange Information, FACTA- real life situations BEPS Action-7- Artificial Avoidance of PE- EPC contracts, Anti Fragmentation, Preparatory auxiliary activities, Commissionaire arrangements, e-commerce Transaction Transfer Pricing, Tax Litigation- Future Scenario Tax litigation future scenario, Dispute Resolution Panel, Bi-lateral APA / MAP Block Chain Technology Crypto Currency A galaxy of eminent speakers from India and abroad will address a wide variety of topics relating to international taxation and transfer pricing. The broad programme outline is attached herewith. The Conference would be attended by lawyers, tax practitioners and other professionals, senior Government officials, tax executives, etc. from across the globe. The Conference would provide an excellent opportunity for exchange of views and knowledge sharing in the area of international tax policy and dissemination of information regarding developments in tax jurisprudence. The registration fee is as under: Category Indian Participant (INR) Foreign Participant (USD) IFA member 10, Non IFA member 12, YIN IFA member 8, Fees are inclusive of 18% To register for the conference you may drop an at shelly.wadhwa@ifaindiaacademy.in along with your contact number. We shall soon be opening the online registration for the conference. As only limited seats are available, I would urge that you register at the earliest. I look forward to meeting you at the Conference. Best regards, Ajay Vohra Conference Chairman Care :Vaish Associates, Advocates Mohan Dev Building (1 st Floor) 13, Tolstoy Marg New Delhi (India) Phone: (Direct) Phone: (Board) Fax:

2 INTERNATIONAL TAX CONFERENCE 2018 CHANGING WORLD ORDER AND INTERNATIONAL TAXATION April 27-28, 2018, The Lalit, New Delhi CONFERENCE PROGRAMME Friday, April 27, 2018 Timings Description Speaker / Panelist Registration Conference opening Welcome Address Ajay Vohra, Senior Advocate & Conference Chairman Inaugural Address Bob Stack, Deloitte* Key Note Address Suresh Prabhu, Minister of Commerce & Industry* Message from IFA President Murray Clayson* Vote of Thanks VP Gupta, Vice Chairman, IFA-India Branch Plenary 1 : BEPS Action 1, Report on Digital Economy - PE issues and impact on Developing countries Chairman : Justice Vineet Kothari Dinesh Kanabar (Moderator) Akhilesh Ranjan, (CBDT)* Pranav Sayta (EY) Ms.Shefali Goradia (Deloitte) Gary Gowrea (Mauritius) Amar Mehta (Canada) Refreshment Break

3 Plenary 2 : BEPS Action 15 - Multi-lateral Instrument Global Harmonization and Enforcement Luncheon address Push towards Digital Economy, followed by lunch Plenary 3 : Introduction and Enhancement of GAARs in Asia and Effect and Consequences for Treaty Shopping / Treaty Abuse case studies Refreshment Break Plenary 4: Global tax developments - U.S. tax reform: Base Erosion Anti-Abuse Tax (BEAT); Foreign-derived Intangible Income and Global Intangible Low-Taxed Income; Australian Federal Court decision in the case of Tech Mahindra Ltd.; Exchange of Information, FACTA real life situations Chairman : Eminent Speaker Gokul Chaudhary (Moderator) Sanjiv Chaudhary (KPMG) Rajat Bansal (IRS) Maikal Evers, OECD, France* Rashmin Sanghvi, CA Ajay Prakash Sawhney, Secretary, IT & Electronics Chairman : Justice (Retd.) R. V. Easwar Ajay Vohra (Moderator) Arvind Datar, Sr. Advocate Padam Kincha, CA Ms. Heather Gething, (UK) Dr. Vikram Chand Paul McNab, (PwC Australia) Farokh N. Subedar (Tata Sons) Sushil Lakhani, Chairman, IFA India Branch Rakesh Nangia, Nangia & Co. Chairman : Nishith Desai, Advocate Abhishek Goenka (PwC) (Moderator) Lloyd Pinto (GT) Paul McNab (PwC Australia) S. Krishnan Ms. Bhattasali (CBDT)*

4 Conference Programme Saturday, April 28, 2018 Timings Description Speaker / Panelist Plenary 5 : : BEPS Action 7 Artificial Avoidance of PE EPC contracts, Anti Fragmentation, preparatory auxiliary activities, commissionaire arrangements, e-commerce Transaction Refreshment Break Plenary 6 : Transfer Pricing (Post BEPS Scenario - CbCR, Business restructuring, Business restructuring and Permanent Establishments, restructuring of intangibles, Profit Split Applications in Practice ) Chairman : Justice Vibhu Bakhru Vishal Anand (Moderator) Pramod Kumar (ITAT) Rohinton Sidhwa (Deloitte) Ms.Daksha Baxi (Khaitan) Amar Mehta (Canada) Vikas Vasal (GT) TP Ostwal, TP Ostwal & Associates Sanjeev Sharma (IRS) Chairman : Justice Ravindra S. Bhat Rahul Mitra (Moderator) Vijay Iyer (EY) Antonio Russo / Sanjiv Malhotra (Baker & McKenzie)* Yuri Matsubara, Japan Rupak Saha (GE) Sam Sim (Singapore) Amit Shukla (ITAT) Ms. Malathi Sridharan (IRS)* Luncheon address by an eminent personality Harish Salve, Sr. Advocate*

5 Plenary 7 : Tax Litigation Future scenario (Arbitration, Dispute Resolution, Bilateral, APA, MAP Refreshment Break Chairman : Justice A.K. Sikri Mukesh Butani (Moderator) V. Lakshmikumaran (L&S) Gurbachan Singh (Singapore) Kyung Geun Lee, Yulchon, Korea Pramod Kumar, ITAT Ms. Pallavi Shroff (CAM) Kamlesh Varshney (IRS) Pallavi Bakhru, Vedanta Plenary 8 : Block chain technology-crypto currency Chairman : Justice S. Muralidhar Kuntal Dave (Moderator) Sajan Poovayya, Sr. Advocate Ms. Sonia Mathur, Sr. Advocate Sam Sim (Singapore) Ms. Shikha Mehra, Global Jindal Speaker from Nishith Desai & Associates* Close of Conference *To be confirmed

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