BEPS @ 5 - Taxsutra...accuracy and unrivaled speed. Taxsutra is the leading B2B tax portal based out...

BEPS @ 5At the Cusp of a Grand Bargain...

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Welcome Note

Let us rewind our memories by exactly 5 years... A rainy day it was in India, a warm bright summer day in Europe...the fateful day when OECD announced, to a lot of

surprise and a fair amount of skepticism, the BEPS project aka Mission BEPS! The five years since have been in fast forward mode, with the OECD & G-20 being relentless in their pursuit of a new international tax order, a fairer tax policy regime with a ‘take no prisoners’ approach to ending tax avoidance by global Multinational Corporations!

We sure have come a long way in these 5 years... 15 BEPS Action Plans, 80+ countries signing on to the historic Multilateral Instrument, Automatic Exchange of Information the new norm, CbCR & Transparency the new buzz words! But there is an old adage - the more things change, the more they remain the same... sample these - the digital tax conundrum, the PE riddles & not to mention the more than a few instances of countries, charged up by BEPS, marching unilaterally to implement some of the measures. Add to it the elephant in the room - United States of America... ! Be it as it may, the progress has been undeniable and the strong winds of change could soon convert into Category one ‘Hurricane BEPS!’

The fourth edition of the Taxsutra Conclave will serve you a platter full of the hottest topics in the world of international tax. Just as we have in the previous three editions, an ensemble speaker line-up will keep the delegates glued to their seats with thought provoking technical sessions, that shall do a lot more than merely scratch the surface of international tax controversies!

Why attend the Taxsutra Conclave?

Thought leadership on

carefully designed

technical-subject panels

Hear from tax policy-makers, tax experts &

tax administrators

Interact with

250 Tax Heads

& CFOs

Conclave Speakers

Andrew Dawson

(Adv

isor, O

ECD’s

Tax T

reaty

Unit)

(Retire

d Jud

ge, F

edera

l Cou

rt of

Austra

lia)

Justice Tony Pagone (Que

en’s

Couns

el)

Philip Baker

Hon. Dr. Justice Anita

Sumanth

(Judg

e, Mad

ras H

C)

(Dep

uty D

irecto

r, OEC

D Cen

tre

for Ta

x Poli

cy an

d Adm

inistr

ation

)Grace Perez-Navarro

Akhilesh Ranjan(Pr

. CCIT,

Inter

natio

nal T

ax &

Trans

fer Pr

icing

)

Sam Sim

(Tran

sfer P

ricing

Geo

Lead

er

EMEA

, Asia

-Pac &

Japa

n, IBM

) Mohan Parasaran(Fo

rmer

Solic

itor G

enera

l of

India)

Arvind Datar

(Senio

r Adv

ocate

)

P. R. Ramesh

(Cha

irman

, Delo

itte In

dia)

Pramod Kum

ar

(Hon

oura

ble M

embe

r, ITA

T)

(Joint

Secre

tary,

Ministr

y of

Finan

ce, In

dia)

Rajat Bansal

N. Venkataraman

(Senio

r Adv

ocate

)

Porus Kaka

(Senio

r Adv

ocate

)

(APA

Com

mission

er)

Ashish Kumar


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Conclave SpeakersSession Moderators

(Delo

itte In

dia)

Gokul Chaudhri

Dinesh Kanabar (D

hruv

a Adv

isors

LLP)

Vinay Sethi

(Thom

son R

euter

s)

Sanjiv Malhotra (Ba

ker &

McK

enzie

)

Rohit Jain

(ELP)

Rakesh Nangia

(Nan

gia A

dviso

rs LLP

)

Ketan Dalal

(Katal

yst A

dviso

rs LLP

)

Uday Ved

(KNAV)

(CNBC

TV18

)

Shereen Bhan

K.R. Sekar

(Delo

itte In

dia)

Girish Vanvari

(Tran

sacti

on Sq

uare)

(Laksh

mikumar

an &

Sridh

aran

)V. Lakshm

ikumaran

Manoj Pardasani (T

rans

fer Pr

icing

Expe

rt)

Manish Shah

(CIT,

Inter

natio

nal T

ax)

Kamlesh Varshney

(Com

mission

er, G

ST)

Upender Gupta

Ajay Vohra

(Senio

r Adv

ocate

)

Rajesh Ramloll

(Dep

uty So

licito

r-Gen

eral,

Mauriti

us)

(Foun

der, B

MR Leg

al)

Mukesh Butani

Rohan Shah

(Adv

ocate

)

T. P. Ostwal

(Mem

ber, U

N Com

mittee o

n

Trans

fer Pr

icing

)

Padamchand Khincha

(Inter

natio

nal T

ax Ex

pert)

Gautam Doshi

(Relia

nce A

DA Gro

up)

P. V. Srinivasan

(Cor

pora

te Adv

isor)

Kartikeya Dube

(Tax D

irecto

r, Ind

ia, M

iddle

East

and S

outh

Asia, B

ritish

Petro

leum)

Pallavi Bakhru

(Gro

up H

ead o

f Tax

,

Veda

nta Lt

d)

(Hea

d – Ta

xatio

n, Cair

n Ind

ia

Limite

d)

Navin Jain

Vinay Mangla

(Hea

d of T

ax, G

oogle

India

) Vineet Agrawal (G

roup

Hea

d, Ta

xatio

n, JS

W

Steel

Ltd)


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Conclave Agenda

5 Taxing Digital Economy Business Models - Can the OECD/ EU Pin Down their Target?

• How to minimize double taxation Digital Business Models?• Unique country approaches in taxing digital business models• Applying digital PE thresholds (users, contracts, revenue) to the new-world business models• Application of India’s Significant economic presence (SEP) principles & thresholds to traditional and

digital business• Value creation analysis in Digital Business Models• Role of data privacy laws in shaping Digital taxation policy

6 AI & Robotics - How Technology is Disrupting the Tax Function

• Overview of AI applications in data-driven businesses• Application of technology solutions in Taxation - for companies, for advisors and for the Revenue• Break-through ideas in Tax Technology• Business case studies on the application of AI and robotics• Role of tax professionals in the era of technology disruption• How is Revenue leveraging the technology in tax administration?

7 The VUCA World of Tax Litigation - Avoiding a Crash Landing!

• Global and Indian trends in tax litigation• Enhanced transparency, analytics and e-assessment - changing dynamics of assessments• Strategies for managing VUCA of tax litigation• Bracing for the crash landing - 5 things corporate tax directors should do in today’s environment.

8 GST–Pathtoasimplifiedregime

• Simplification of Returns system• Amendments to GST legislations – removing ambiguities• Litigation – Advance rulings (100+ decisions with differing views, unsettling the settled positions /

principles), writ petitions challenging constitutionality of various provisions• Assessments & Audit – the way ahead• Role of Technology, fate of GSPs and ASPs• Anti-profiteering – need for clear guidelines?• Malaysian experience – Learnings / Glimpse at GCC VAT

1 Keynote Panel : BEPS @5 - At the Cusp of a Grand Bargain

• The Progress So Far• Have the original objectives been met?• BEPS implementation in EU, BRICS & USA• International Structures - The Post BEPS Landscape• The Unfinished Agenda

2 Structuring & Restructuring in a BEPS World

• Practical Insights on how Structuring and Restructuring decisions are made in Post-BEPS World

• Case Studies on evolving Business Models in response to BEPS Risks (Residency Tests, PE Risks, TP Structures, R&D Activities etc.)

• Grandfathering of Existing Structures in the Post-BEPS World• Will Tax Planning involving Holding Structures, SPVs still stand

in the face on BEPS measures?

3 Alternate Dispute Resolution - Getting Ready for Tax Arbitration

• Arbitration - Global Trends• Case Studies • Arbitration under BIPA - Indian Revenue’s Approach• Learnings from Commercial Arbitrations• Practical Guide - Engaging a Law firm, Voluminous

Documentation & Negotiations

4 Permanent Establishment - The Shifting Sands

• Revisiting PE thresholds under treaties for traditional businesses

• PE Rulings in India & Abroad - Is the Revenue gaining momentum?

• Parsing the Revenue Approach in FAR Analysis • Service PE - Would virtual services constitute a PE?


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Conclave Workshop Do not miss out our special full day workshop on Thursday, October 11. The workshop shall feature well known tax experts who shall throw light on the finer aspects of several complicated tax issues.

Workshop Topics1. Significant Economic Presence (SEP) - Direct Tax Impact on Businesses

2. Managing the Tax Function

3. IBC – 5 Game-changing Provisions in the Law and its Impact on Tax, Trade, M&A and Business

4. Developments on US State Taxes affecting Indian Outbound Business

Conclave StructureThe Conclave shall be structured with panel discussions around the above topics. The structure of the panel will ensure an all-round coverage with speakers from industry, tax consultants, IRS. The time available for each panel shall be between 75-90 minutes.

Conclave Dates11th, 12th & 13th October, 2018

Delegate Registration The Taxsutra Conclave aims to see the participation of 250 Tax Heads and CFOs, who shall be extended complimentary-delegate passes. CFOs & Tax Head of Corporates can send their request to [email protected] from their official email address with the following details: Name, Company name, designation, Mobile number and your official email ID. You shall receive a confirmation mail from Taxsutra team.

Advisors, Counsel, Consultants, Other Executives and all those in Private Practice can also attend.

Get in touch with our Events team at: [email protected] or

call Fahad Khan @ 91- 9920934596

Conclave Venue The beautiful setting of the Oberoi at Gurgaon in the NCR region - voted as the World’s leading luxury hotel in 2013, shall serve as the backdrop as we welcome eminent Indian and international speakers and 250 corporate tax heads & CFOs.


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Moments from Taxsutra Conclave 2017: ‘BEPS and Beyond – The Dawn of a New Era’

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Taxsutra Edge:

Over the last 7½ years, Taxsutra has been delivering the fastest Tax news, insights and commentaries with unquestionable accuracy and unrivaled speed. Taxsutra is the leading B2B tax portal based out of India and its thought leadership has been reflected in a series of cutting edge Editorial Insights, specifically its coverage on BEPS, APA, IFA Congress, Vodafone tax case, Union Budgets, Soccer & Tax microsite, etc. Taxsutra reaches out to the who’s who of the tax world that includes over 10000 Tax professionals in India, leading MNCs, several hundred Corporate Tax Heads, senior Government officials and overseas Tax professionals.

Conclave Partners

RealtimeTaxsutra Services Pvt LtdLokmanya House, Office No.2, First Floor, Plot No. 44, Sr. No. 89, 90 / 950, Lokmanya Colony,Next to CNG Pump, Paud Road, Pune 411038. • Tel: 8055509241


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BEPS @ 5 - Taxsutra...accuracy and unrivaled speed. Taxsutra is the leading B2B tax portal based out...

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