Foundation for International Taxation
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FOUNDATION FOR INTERNATIONAL TAXATION
TRAINING PROGRAMME: APRIL 09 – JUNE 04, 2011
SUBJECT: INTRODUCTION TO INDIAN TAX TREATIES UNDER DOMESTIC INTERNATIONAL TAX & CASE LAWS
Background:
The Foundation for International Taxation (FIT) has organised its 2011 training Course on Indian Tax Treaties this summer. It is given by some of the leading Indian professional experts on the subject. They have been selected not only for their knowledge and subject expertise but also their ability to teach the subject. Moreover, the course fee has been kept low to make it more affordable.
This basic course is meant for professionals in industry as well as in practice with limited or no knowledge of Indian tax treaties. No prior knowledge of the subject is assumed. However, the knowledge of Indian domestic tax laws is desirable. At the end of the course, the attendees will have an overview of the theory and practice of Indian tax treaties under international model treaties as well as under domestic tax law and judicial decisions in India.
The Foundation for International taxation will also award an official certificate of attendance to all attendees on successful completion of the course.
Location and Timing:
The course will be held under the supervision of Mr T P Ostwal, one of our trustees, on nine Saturdays during the period from April 09, 2011 to Jun 04, 2011 at the Xavier Institute of Management and Research.( 3rd Building), St.Xavier’s College Campus, 5 Mahapalika Marg, (Next to Cama Hospital), Mumbai – 400 001. (Tel - 91 22 6522 1909 / 1911 Fax- 91 22 2265 06070
Fee
As a basic course the fee has been kept low at Rs 15000 for these lectures. This cost includes a complimentary copy of two Volumes of the book “Basic International Taxation” by Professor Roy Rohatgi, published by Taxmann in India (published price: Rs 4,500) plus a copy of the latest version of the OECD Model Treaty and Commentaries reprinted in India by the Bombay Chartered Accountant Society (published price: Rs 500). In addition, it will cover the cost of snacks and lunch during the lectures and the cost of the handouts and other course materials besides direct course expenses.
Registration:
For registration please complete the attached form and send it with your fee to
Foundation for International Taxation
109 Marine Chambers, 43 New Marine Lines
Churchgate, Mumbai 400020
Tel/Fax: 022 6610 1964/1965
Email: [email protected]
In case you have any questions please contact me.
Uma Sathnur
(Executive Secretary) COURSE OUTLINE
The course is based on two sessions held every Saturday over a period of two months, as follows;
TOPICS
1. ARTICLES 1, 2 & 3 – ORIENTATION,OVERVIEW OF DTAA SCOPE,
TAXES COVERED AND DEFINITIONS
Date: April 09, 2011 Lecturers: T P Ostwal & Girish Dave Time: 9.30 – 13.00
2. INDIAN TAX TREATIES –HISTORY, TREATY POLICY AND MODEL TREATIES
Date: April 09, 2011 Lecturer: Roy Rohatgi Time: 14.00 – 17.00
3. ARTICLE 6 & 8 - IMMOVABLE PROPERTY AND SHIPPING PROFITS
Date: April 16, 2011 Lecturer: Kuntal Dave Time: 10.00 – 13.00
4. CONTROLLED FOREIGN CORPORATION RULES & DIRECT TAX CODE BILL
Date: April 16, 2011 Lecturer: Shabbir Motorwala Time: 14.00 – 17.00
5. ARTICLE S 10, 11 & 13 – DIVIDENDS, INTEREST AND CAPITAL GAINS
Date: April 23, 2011 Lecturer: Hema Lohiya Time: 10.00 – 13.00
6. ARTICLES 15 & 16 – EMPLOYMENT AND PROFESSSIONAL INCOME
Date: April 23, 2011 Lecturer: Hitesh Sharma Time: 14.00 – 17.00
7. ARTICLE 12 – ROYALTIES AND FEES FOR TECHNCIAL SERVICES
Date: April 30, 2011 Lecturer: Sunil Choudhary Time: 10.00 – 13.00
8. ARTICLES 18, 19, 20, 21 & 22 – PENSIONS, STUDENTS, OTHER INCOME AND
SPORTSMEN & ARTISTS
Date: April 30, 2011 Lecturer: Mayur Nayak Time: 14.00 – 17.00
9. ARTICLE 23 – RELIEF FROM DOUBLE TAXATION
Date: May 07, 2011 Lecturer: Sharad Jain Time: 10.00 – 13.00
10. ARTICLE 9 – TRANSFER PRICING IN INDIA & THIN CAPITALISATION RULES
Date: May 07, 2011 Lecturer: Vispi T. Patel Time: 14.00 – 17.00 11. LIMITATION OF BENEFITS AND ANTI AVOIDANCE AND GAAR IN DTC
Date: May 14, 2011 Lecturer: Mrugen Trivedi Time: 10.00 – 13.00
12. INTERNATIONAL TAX PLANNING – SOME GUIDELINES
Date: May 14, 2011 Lecturer: Sarika Dhameja Time: 14.00 – 17.00
13. INDIAN TAX TREATY INTERPRETATION UNDER INDIAN COURTS
Date: May 21, 2011 Lecturer: Girish Dave Time: 10.00 – 13.00
14. ARTICLES 6, 8, 14 & 17 – BUSINESS INCOME
Date: May 21, 2011, Lecturer: Vishal Gada Time: 14.00 – 17.00
15. ARTICLES 24 TO 30 - OTHER ARTICLES (EXCHANGE OF INFORMATION, MUTUAL
AGREEMENT PROCEDURE, COLLECTION OF TAXES OF OTHER STATES,
NON-DISCRIMINATION, ETC.
Date: May 28, 2011 Lecturer: Keyur Shah Time: 10.00 – 13.00
16. TRANSFER PRICING: SOME PRACTICAL ISSUES IN INDIA
Date: May 28, 2011 Lecturer: Karishma Phatarphekar Time: 14.00 – 17.00
17. ARTICLE 4 – PERSON AND RESIDENCY UNDER TAX TREATIES
Date: June 04, 2011 Lecturer: Sushil Lakhani Time: 10.00 – 13.00
18. ARTICLES 5 & 7 – PERMANENT ESTABLISHMENT & ATTRIBUTION OF PROFITS TO PE
Date: June 04, 2011 Lecturers: Mrugen Trivedi & Jayesh Karia Time: 14.00 – 17.00
END OF COURSE
Note: The speakers and topics may be liable to change due to unforeseen circumstances. SPEAKER PROFILES
Girish Dave: Girish retired as Chief Commissioner of Income-tax from Mumbai in early 2010 after serving in the Income tax Department for more than three decades in various capacities. He was Director of Income tax (International Taxation) Mumbai from the year 2005 until 2009, where he was involved with several major international tax cases (e.g. Vodafone, IHHI, SET, etc.). His main areas of interest are tax investigation and representation.
Kuntal Dave: Kuntal is the proprietor of his firm, Nanubhai Desai & Co. in Mumbai. He actively advises clients on various corporate restructuring matters and on foreign collaboration arrangements with innovative tax efficient and legally compliant strategies. He is the Chairman of Young IFA Network (YIN), IFA Netherlands. He is also the honorary secretary of IFA India Branch and also of Western Regional Chapter of IFA India Branch. He is member of the Direct Taxation Committee of the Indian Merchants’ Chamber.
Vishal Gada: Vishal is a Director in KPMG India's tax & regulatory practice. He specialises in International Taxation and Regulatory Laws concerning cross-border transactions and inbound as well as outbound Investments. He focuses on the Telecom, Technology and Media-Entertainment Sector and advises some of the leading players in these Sectors.
Sharad Jain: Sharad leads the global business advisory service team as partner of the firm, T.P. Ostwal & Associates. He advises clients on a wide range of issues involving non-resident taxation, cross border transaction structuring, inbound and outbound investments, and transfer pricing planning and compliance. He was co-author of Indian branch report on ‘Group Taxation’ for IFA Austria Conference.
Jayesh Kariya: Jayesh is a Partner in the Infrastructure, Real Estate & Government Group of KPMG in Mumbai with over 20 years professional experience. He has advised major multinational clients and has developed significant expertise and strong understanding of global tax and regulatory ramifications of cross-border transactions. He lectures frequently cross-border taxation issues.
Sushil Lakhani: Sushil is the founder of his proprietary firm, Lakhani & Associates, a chartered accounting firm with diversified practice in international tax and FEMA. He has almost three decades of post qualification experience in taxation. He has been a faculty member at several courses and seminars, and has authored many books and articles on international tax issues. He is presently the Vice President of the IFA - India Branch.
Mayur Nayak: Mayur is the proprietor of his firm, MB Nayak & Co. in Mumbai. He is a specialist on issues involving international taxation (including transfer pricing), cross-border investments and Foreign Exchange Management Act (FEMA). He is currently the President of the Bombay Chartered Accountants’ Society. Over the years, Mayur has authored several books on international taxation and FEMA. In 2005, he was co-author on the Indian Branch Report on “Source and Residence: New Configuration of their Principles” for IFA Congress in Buenos Aires.
T.P. Ostwal: T.P. Ostwal is the senior partner of the firm of T.P. Ostwal & Associates in India. He is Ex Chairman of International Fiscal Association - India Branch, and a Vice President and member of the Executive Committee of IFA based in the Netherlands. He is also a member of the expert group on Transfer Pricing for Developing Countries set up by the United Nations. In 2007, he was ranked as 11th most influential tax professional in the world by Tax Business magazine in the United Kingdom.
Vispi T. Patel: Vispi runs his proprietary firm, Vispi T Patel, based in Mumbai. He has been closely associated with the development of Transfer Pricing law in India since its inception. He advises companies on transfer pricing and international tax issues, including economic strategy, business transformation, transfer pricing documentation, inbound and outbound strategy & structuring of cross border transactions etc. He was recently nominated as India’s leading Transfer Pricing Consultant by International Tax Review –World Tax and by Euromoney Legal Media Group.
Roy Rohatgi: Roy spent several years in Mumbai (Bombay) in the eighties where he established and ran the Indian firm of Arthur Andersen as managing partner. He is a visiting professor in international taxation in several universities. He is the author of the book “Basic International Taxation” (now in its Second Edition). Since 1995, he has been the conference director of the annual international taxation conference organised by the Foundation for International Taxation.
Sunil Choudhary: Sunil is Associate Director, Tax & Regulatory Services, Ernst & Young, India. Prior to joining E&Y in 2007, he worked with BDO Haribhakti as partner. He has more than 17 years of experience in advising various small, medium and large corporate, on domestic, cross border tax issues, exchange control and regulatory issues.
Mrugen Trivedi: Mrugen is an Associate Director in KPMG India's tax practice. He takes care of the Tax Knowledge and Solutions Team in KPMG. He specialises in Corporate Taxation as well as International Taxation concerning cross-border transactions. He is a member of the Direct Tax Committee of the Chamber of Tax Consultants.
Shabbir Motorwala: Shabbir is a Director in the Global International Corporate Tax & Regulatory team of M/s. KPMG in Mumbai with over thirteen years of professional experience. He specializes in corporate-tax, foreign exchange laws, international tax and tax treaties provisions. Shabbir is a regular speaker at tax seminars and conferences on international tax issues in India.
Keyur Shah: Keyur is a partner with the Financial Services tax practice of KPMG India based in Mumbai. He has over 14 years of experience in advising clients on international tax and regulatory issues. He specializes in a wide range of tax services including entry and exit strategies for cross border investments, tax planning, designing and implementing transfer pricing strategies.
Karishma R Phatarphekar: Karishma is a Partner at Grant Thornton India and leads their transfer pricing practice. Prior to joining Grant Thornton in 2004, she worked with PricewaterhouseCoopers for more than five years on transfer pricing compliance issues. Her other areas of experience deal with tax and regulatory compliance on a wide range of international tax matters. She has also worked in the Corporate Finance division of an international Investment bank. She is a Chartered Accountant and a CPA.
Sarika Dhameja: Sarika is a Director of International Taxation at Deloitte Haskins & Sells in India with over 13 years experience. She has helped many multinational clients on their Indian and International tax projects and issues. She also provides tax advisory services for setting up of businesses in India, structuring of transactions, repatriation strategies, etc.
Hema Lohiya: Hema is a senior manager in the Mumbai office of Deloitte Haskins & Sells with over ten years experience in international tax and exchange control regulation. Her experience covers structuring of cross-border investments into India and outside India, advising on cross border transactions, setting up tax efficient offshore structure etc.
Hitesh Sharma: Hitesh works as a tax manager in the international assignment services division of PricewaterhouseCoopers (PwC) in Mumbai. He specializes in individual taxation and cross-border taxation matters involving mobile employees. Over the years, he has worked extensively on employee compensation matters and reward plans for Indian and foreign companies.
March 2011
Mumbai
TRAINING PROGRAMME ON BASIC INTERNATIONAL TAXATION
Date: 9th April to 4th Jun 2011 (9 Saturdays) Time: 09.30 am to 17.30 pm Venue: XAVIERS INSTITUTE OF RESEARCH MANAGEMENT, MUMBAI, INDIA Organized by the Foundation for International Taxation (F.I.T.) (website: www.fitindia.org)
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Course Fee: Rs. 15,000/- plus Service Tax at 10.30% of Rs 1545 e.g. Rs 16545 Group Discount: Rs 12500/- plus Service Tax at 10.30% of Rs 1288 e.g. Rs 13788 for group of 5 or more to members from same business or professional organisation
Note: The fee once paid is not refundable The rupee amount is exclusive of service tax. An additional amount @ 10.30% is payable by Indian delegates. For the foreign delegate the fee amount is inclusive of Indian service tax of 10.30%. Our Service Tax Registration No.ST/Mumbai/COV/Dn/II/36/2006. There is no TDS requirement. If you require a receipt please tick: YES/NO
Please send this form by post, e-mail or fax with delegate fee to the Foundation for International Taxation Attn: Uma Sathnur, 109, Marine Chambers, 43, New Marine Lines, Churchgate, Mumbai 400020, India Email: [email protected]; Tel: 91 - 22 6610 1964/65 Telefax: 91 - 22 6610 1964/65