14TH RESIDENTIAL CONFERENCE ON INTERNATIONAL TAXATION
June 18 @ 12:00 pm - June 21 @ 2:00 pm
|INTERNATIONAL TAXATION COMMITTEE|
|Chairman :||Rajesh L. Shah|
|Vice Chairman :||Kirit Dedhia, Harshal Bhuta|
|Convenors :||Isha A. Shekhri, Ronak Doshi, Kartik Mehta|
|Advisor :||Dilip J. Thakkar|
|RRC Mentor :||Dilip J. Thakkar, T. P. Ostwal, Padamchand Khincha|
|Conference Directors :||Shreyas Shah, Kartik Mehta|
Keeping in mind the words of Benjamin Franklin, “An investment in knowledge always pays the best interest”, along with the ever changing and dynamic web of international taxation, the 14th Residential Conference on International Taxation could not come at a better time. Year-after-year, the RRC helps bring together eclectic and experienced professionals as well as young and enthusiastic minds to trade thoughts and ideas, providing a retreat from the mundane lives to reflect upon the continually transforming policies in the tax arena.
In the 14th RRC, we plan to focus on the advanced principles on interpretation of the tax treaty and have revisited the relevance of nexus in terms of distribution rules and attribution rules, and the extent of its paradigm shift, in light of multi-fold developments that has taken place in international tax arena. We will also get an advanced glimpse of how Multinational Companies strategize and restructure their supply chain models, keeping in mind the crossborder commercial and tax considerations. Also, special sessions are planned on the conceptual understanding of the arm’s-length principle in comparison with the OECD Pillar 1 and Pillar 2 proposals; Combined analytical study on various economic laws in India, such as FEMA, PMLA, etc.; and Case-study and Research-study based discussion on international tax issues. Our aim is to have an analytical discussion on micro-level issues and further discussion on planning the way forward.
The 14th Residential Conference on International Taxation will be held from Thursday, 18th June, 2020 to Sunday, 21st June, 2020 at Alila Diwa Goa, and promises to be an exciting event for a thorough exchange of knowledge and ideas in this evolving field.
From its gorgeous beaches and lush paddy fields to its rich heritage and traditions rooted in its colonial past, Goa offers a wondrous mix of nature, culture and lifestyle to take a much-needed breather and experience this unique conference.
About Hotel Alila Diwa Goa:
Alila Diwa Goa, a five star resort and part of Hyatt Group offers a beautiful Balinese-style property set amongst coconut groves and surrounded by verdant rice paddies. Off-site meetings take on a whole new meaning with Alila Diwa Goa’s ‘Leisure Conferencing’ concept, with its magnificent meeting spaces and its detailed oriented service team.
|Day & Date||:||Thursday, 18th June, 2020 to Sunday, 21st June 2020|
|Venue||:||Alila Diwa Goa, 48/10, AdaoWaddo, Majorda, Goa-403713|
The outline of the topics to be discussed at the conference is as under:
|Sr. No.||Group Discussion||Speakers|
|1||An Art yet to be Mastered: Advanced Principles on interpretation of key tax treaties in light of recent developments.
(i) To understand the approach to define the undefined terms (Art. 3(2) and its corresponding interpretation issues.
(ii) Relevance of the OECD Commentary and the MLI explanatory statement from an Indian judiciary perspective; and interpretation issues in Trianguar and Tax paring situations.
|CA Gautam Doshi|
|2||Emerging concept of nexus in the context of business and its paradigm shift, other than digital taxation.
(i) Changing concept of ‘operations in India’ from the perspective of business connection and permanent establishment.
(ii) Relevance of ‘effectively connected’ to PE in terms of Royalties, FTS.
(iii)To note the differences and similarities of nexus for each income under different classification rules.
|CA Padamchand Khincha|
|3||Cross-border supply-chain strategies and restructuring options, focusing on prudent manufacturing & distribution practices.
(i) From the perspective of mitigating Permanent Establishment risks and other tax risks, considering PPT / GAAR
(ii) From the perspective of multi-classification of income under the Act and under the Tax Treaty.
(iii) From the perspective of Full-fledged business model, Outsourced Model, Franchise model or Licensed Model (including use of EULA for software sale)
|Senior Eminent Faculty|
|1||Finding the right balance: Tax transparency and Protection of taxpayers’ rights (including those of consultants and non-executive directors)
(i) Judicial precedents that protects Entrepreneurs’ that rely on tax advisor’s opinion; past decisions covering on similar matter.
(ii) Judicial precedents on curtailing territorial nexus, from the perspective of digital business, etc.
(iii) Noting risk factors when non-executive director is proposed to be the chairman (separate from CEO/MD) under the Listing Rules
|Hon’ble Vice President of ITAT Shri Pramod Kumar|
|2||Discussion on the OECD Unified Approach
(i) OECD Pillar 1 and Pillar 2 proposals
(ii) Comparison with the emerging concept of ALP and nexus rules.
|CA Shefali Goradia|
|3||Use of data (including from CBCR, TIEA, use of technology, etc.)
for determining evasion
|Fire side chat by
CA T. P. Ostwal with
Mr. Akhilesh Ranjan, Ex- Member, CBDT
|4||Issues relating to Royalties – use of Patent, Software and
|CA Himanshu Parekh|
|1||Understanding actions across different economic laws: PMLA, Black Money, Benami, Corporate Laws||CA Dilip J. Thakkar, CA Dr. Dilip K. Sheth & Senior Eminent Faculty|
|2||Case Studies on attribution of business profits, with DEMPE and FAR analysis and attribution data points (including digital taxation)||CA Vispi Patel & CA Shefali Goradia|
|3||Case Studies on International Taxation (including issues on High Net Worth Individuals)||CA Pinakin Desai, CA T. P. Ostwal, CA Dilip Choksi & Shri S. Ganesh, Senior Advocate*|
*Subject to Confirmation
A host of entertainment activities have been planned as well.
Fees structure for residential participants is under:
Residential participants – Twin sharing room.
|Particulars||Up to 12th March, 2020||From 12th March, 2020|
|MEMBERS||₹ 19,000/- + ₹ 3,420/- (18% GST) = ₹ 22,420/-||₹ 21,000/- + ₹ 3,780/- (18% GST) = ₹ 24,780/-|
|NON-MEMBERS||₹ 20,000/- + ₹ 3,600/- (18% GST) = ₹ 23,600/-||₹ 22,000/- + ₹ 3,960/- (18% GST) = ₹ 25,960/-|
The fees include
• Pick up and drop facility to and fro from airport/Madgaon Railway Station, subject to advance intimation
• 3 Nights-4 days accommodation on double occupancy basis
• All meals starting with lunch on 18th June 2020 and ending with lunch on 21st June 2020.
• Course Material
1) RRC will commence from lunch at 1.00 p.m. on Thursday, 18th June, 2020 and end by 2.00 p.m. (after lunch) on Sunday, 21st June, 2020.
2) Check-in time at hotel is 1.00 p.m. (subject to availability of rooms) on Thursday, 18th June, 2020. The sessions will start at 3.00 p.m. on Thursday, 18th June,
2020. Participants are requested to book tickets accordingly.
3) Registration is on first-come-first basis and is restricted to 210 participants.
4) In case of cancellation, no refund request will be entertained, except under genuine unavoidable circumstances, subject to approval of the Managing Council
of The Chamber.
5) Interested members may enrol from the Chamber’s website www.ctconline.org to make online payment. Members can also download the “Form” from the
Chamber’s website www.ctconline.org or may collect it from The Chamber’s office and send it along with the cheque/DD/Pay Order in favour of “The
Chamber of Tax Consultants”.
6) Outstation members are requested to make the payment by At Par Cheque / Demand Draft only or can make online payment through the Chamber’s website
www.ctconline.org. Delegates making online payment should ensure that their Enrolment forms reach CTC Office within 3 days of payment made
7) For further details delegates may contact the following:
Shreyas Shah: 9819885321 | Kartik Mehta: 9833218700 | Kirit Dedhia: 9833597056 | Hitesh Shah (Chief Manager CTC): 9821889249