IBFD 5 th Africa Tax Symposium

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IBFD 5 th Africa Tax Symposium 29 31 May 2019 Hotel Spier, Stellenbosch, South Africa Technical Programme This symposium is an initiative of the IBFD Centre for Studies in African Taxation, a think tank devoted to the study and development of African taxation.

Tuesday, 28 May Pre-Symposium - Arrival, Registration and Cocktail Reception 12:00-17:00 Arrival and Registration 19:00-22:00 Cocktail Reception Day 1: Wednesday, 29 May Registration and Opening Ceremony 08:00 08:45 Registration and accreditation 08:45 09:15 Official Welcome and Goodwill Messages by Cooperating Partners 09:15 09:45 Keynote Speech Belema Obuoforibo, Director of the Knowledge Centre and Member of the Executive Board, IBFD, the Netherlands Jan Maarten Slagter, Chief Executive Officer, IBFD, Netherlands Jennifer Roeleveld, University of Cape Town, South Africa TBC 09:45 10:30 Refreshments & Photo Session Session 1: Recent Developments in International Taxation 10:30 10:40 Opening Remarks Session Chair Parthasarathi Shome, ITRAF, India 10:40 11:00 The UN Model Tax Convention 2017: An Analysis of the Latest Revisions Michael Lennard, Chief, International Tax Cooperation, FDO, United Nations, United States 11:00 11:20 Implementing the OECD BEPS Project in Africa: Lessons and Experiences TBC 11:20 11:45 Questions and Discussion Session 2: Africa s Tax Treaty Network: A Critical Analysis 11:45 11:55 Opening Remarks Session Chair Belema Obuoforibo, Director of the Knowledge Centre and Member of the Executive Board, IBFD, the Netherlands 2

11:55 12:15 Treaties with Investment Hubs: Critical Considerations Mohammed Y. Jada, Africa Leader, Business Tax Services, EY, South Africa 12:15 12:30 Africa s Tax Treaty Network: Middle East Focus Mohamed Faycal Charfeddine, Group Tax Manager, Aujan Group Holding, Dubai, UAE 12:30 12:45 The MLI Impact: Policy, Legal, and Practical Considerations for Africa Ridha Hamzaoui, Managing Principal, Middle East and North Africa, IBFD, the Netherlands 12:45 13:00 Questions and Discussion 13:00 14:30 Lunch Session 3: Current Issues in International Taxation 14:30 14:40 Opening Remarks Session Chair Lazelle Terblanche, Head of Tax, Multi-Choice and Chairperson, Africa Industry Tax Association, South Africa 14:40 15:00 International Tax Structuring and Planning, Post-BEPS: Global Trends Peter Dachs, Director, ENSafrica, Cape Town, South Africa 15:00 15:20 International Tax Structuring and Planning, Post-BEPS: The African Perspective Theophilus I. Emuwa, Partner, AELEX, Nigeria 15:20 15:40 Addressing Tax Avoidance through the Courts and Legislation: An Overview of Recent African Experiences Johann Hattingh, University of Cape Town, South Africa 15:40 16:00 Dispute Resolution through the Tax Courts: Lessons from India Justice PP Bhatt, President of the Income Tax Appellate Tribunal (ITAT), India 16:00 16:30 Questions and Discussion 16:30 17:00 Refreshments Day 2: Thursday, 30 May Session 4: Transfer Pricing in Africa 09:00 10:00 Transfer Pricing in Africa: The Post-BEPS Experience (Panel Discussion) Emily Muyaa, Managing Principal, Sub-Saharan Africa & Project Manager, Centre for Studies in African Taxation, IBFD, the Netherlands Ferdinand Nji Tanji, Associate Director, EY, Cameroon 3

George Obell, Chief Manager, International Tax Office, Kenya Revenue Authority (TBC) Taiwo Oyedele, PwC West Africa Tax Leader and President Impact Africa Foundation, Nigeria Vicki Bales M.A., Transfer Pricing Director, DLA Piper, London, United Kingdom 10:00 10:15 Comparability Analysis and the Elusive Search for Comparables: A Case Study Sébastien Gonnet, Transfer Pricing Economists for Development (TPED), France 10:15 10:30 Questions and Discussion 10:30 10:45 Book Launch (Roy Rohatgi on International Taxation) 10:45 11:00 Refreshments Belema Obuoforibo, Director of the Knowledge Centre and Member of the Executive Board, IBFD, the Netherlands Jennifer Roeleveld, University of Cape Town, South Africa Roy Rohatgi, Settlor and ManagingTrustee, Foundation for International Taxation, India Session 5: Host Country Focus: Taxation of the Services Industry in South Africa Selected Issues 11:00 11:10 Opening Remarks Session Chair Chief Mark Anthony C. Dike (FCTI), Past President/Council Member, Chartered Institute of Taxation of Nigeria (CITN) 11:10 11:30 Overview of South Africa s Tax Policy for the Services Industry: Challenges and Lessons Lutando Mvovo, Executive Head: International Tax at Vodacom Group, South Africa 11:30 11:50 Taxation of Electronic Commerce Transactions Aneesa Baig, Director, National Treasury, South Africa 11:50 12:10 Taxation of the Funds Industry in South Africa Elandre Brandt, Head of Group Tax, Imperial Holdings Ltd 12:10 12:30 Taxation of Services and Electronic Commerce Transactions: Perspectives from the Rest of Africa Sebastine Odimma, Head of Tax, Maersk Group Nigeria 12:30 13:00 Questions and Discussion 13:00 14:30 Lunch Session 6: Investing in Africa 14:30 14:40 Opening Remarks Session Chair Daniel Ngumy, Partner, Anjarwalla & Khanna (A&K), Kenya 14:40 15:30 Understanding the African Continental Free Trade Area (AfCFTA) 4

Faizel Ismail, Adjunct Professor UCT School of Economics, Consultant to the DTI (SA) on international trade and a Special Envoy on the AGOA Panellist 2 (TBC) 15:30 16:00 The Winds from the East: A Tax Perspective on China s Foray into Africa 16:00 16:20 Refreshments Ernie Lai King, Managing Director, 1 Road Consulting Limited, South Africa Opening Remarks Session Chair David J. Bakibinga, Makerere University, Uganda 16:20 16:40 Investing in Africa through Mauritius: the Tax Perspective Rajesh Ramloll, Deputy Solicitor General, Mauritius 16:40 17:00 Tax Incentives and Domestic Resource Mobilization: Settling the Misconceptions Annet Wanyana Oguttu, University of Pretoria, South Africa 17:00 17:20 Questions and Discussion 19:30 Symposium Gala Dinner Day 3: Friday, 31 May Session 7: Tax and Technology 09:00 09:10 Opening Remarks Session Chair Izelle Du Plessis, Stellenbosch University, South Africa 09:10 09:30 Taxing the Digital Economy: Overview of Current Global State of Play Walter Andreoni, Tax Partner, Mercanti Dorio e Associati, Italy 09:30 09:50 Taxing the Digital Economy: Lessons from India Ameya Kunte, Taxsutra, India 09:50 10:10 Africa and the Digital Economy: Critical Points for Attention TBC 10:10 10:30 Questions and Discussion 10:30 10:50 Refreshments Session 8: Tax Administration and Tax Technology 10:50 11:00 Opening Remarks Session Chair Duncan Onduru, Executive Director, CATA, United Kingdom 5

11:00 11:20 Equipping Tax Administrations for the Digital World: Lessons for Africa 11:20 12:00 Panel Discussion Julia de Jong, Manager, Government Consultancy Department, IBFD, Netherlands Julia de Jong Carel Gericke, Group Head of Tax, MTN, South Africa Yvonne Wafula, Data Warehouse and Business Intelligence Project Manager, Kenya Revenue Authority Session 9: African Tax Authorities and their Powers of Enforcement 12:00 12:20 Opening Remarks Session Chair Babatunde Oladapo, Executive Secretary, WATAF, Nigeria 12:20 12:40 Exchange of Information: the African Perspective Johanne Hague, Partner, Juristconsult Chambers, Mauritius 12:40 13:00 Protecting Taxpayer Rights in the Era of Exchange of Information: the African Experience Craig West, University of Cape Town, South Africa 13:00 13:20 Questions and Discussion 13:20 Closing Ceremony 14:30 Optional Tours 6