Ralph Cunningham, International Tax Review, Vijay Iyer, partner and national leader, transfer pricing group, Ernst & Young
A proactive approach to managing global transfer pricing disputes can enhance both efficiency and effectiveness. Many countries are therefore adopting advance pricing agreements (APA) programs as a way of addressing evolving transfer pricing issues worldwide — as of July 2012, more than 30 countries allow APAs.
One jurisdiction with the highest rate of transfer pricing litigation activity is India, where a high proportion of taxpayers rely on litigation for resolution of disputes. One obvious reason for this could be the absence of an APA program in India under the current tax law. Realising the severity of the issue, an APA program has been implemented through the last budget amendments.
The webcast will be discussing on APA process, best practices in framing an APA mechanism and update on the recent development in India
Aug 8 2012
80 mins
Navigating Indian APAs
More from this community:

Accounting and Tax

  • Live and recorded (163)
  • Upcoming (12)
  • Date
  • Rating
  • Views
  • Channel
  • Channel profile
  • Guide to High Performing, Compliant and Effective VAT & Excise Tax Management Recorded: Jun 23 2015 65 mins
    Kid Misso, Director of Pre-Sales, Avalara, Nick Castellina, Research Director at Aberdeen Group, Ralph Cunningham, ITR
    Managing VAT and excise tax in the current environment is time consuming, costly, and subject to frequently changing mandates. Recent Aberdeen Group research uncovered key strategies that top performing organisations utilize to ensure compliant processes and accurate reports at a lower cost. Learn secrets of leaders that make tax calculation and returns look easy.

    You will learn about the:

    -Complexity of regulatory change around tax rates and rules
    -Difficulty of achieving accurate calculations
    -Value of reliable reporting for decision-makers
    -Importance of proper audit preparedness
    -Benefits of software solutions that automate accuracy and compliance
  • India Budget 2015 Recorded: Mar 2 2015 91 mins
    Dinesh Kanabar & Rakesh Dharawat, Dhruva Advisors, Udayan Choksi, DhruvaVox, Ralph Cunningham ITR
    The Indian Budget 2015 will be the first opportunity for Prime Minister Narendra Modi and his government to set out in detail how it hopes to create more tax-friendly conditions for investors. Many questions need clarification: Will the GAAR start on schedule? What favourable changes can be made to the direct tax regime to encourage investment? What are the implementation plans for GST and when are they likely to happen? Let Dhruva Advisors and DhruvaVox take you through the main points of the announcement and help you find the answers to these and other issues.
  • India Budget 2015 Recorded: Mar 2 2015 94 mins
    Dinesh Kanabar, Rakesh Dharawat, Udayan Choksi of Dhruva Advisors, Ralph Cunningham ITR
    The Indian Budget 2015 will be the first opportunity for Prime Minister Narendra Modi and his government to set out in detail how it hopes to create more tax-friendly conditions for investors. Many questions need clarification: Will the GAAR start on schedule? What favourable changes can be made to the direct tax regime to encourage investment? What are the implementation plans for GST and when are they likely to happen? Let Dhruva Advisors and DhruvaVox take you through the main points of the announcement and help you find the answers to these and other issues.
  • VAT reforms in China Recorded: Dec 10 2013 75 mins
    Lachlan Wolfers, KPMG, Leader, Center of Excellence, PRC Indirect Taxes & Ralph Cunnnigham, Managing Editor ITR
    Topic title – VAT reforms in China – how do the recent and proposed changes impact on multinational companies
    “The first phase of the VAT pilot program was implemented nationwide in mainland China on 1 August 2013. In this web seminar, we take a look at the key impacts for multinational companies doing business in, or with China. We also look at the future phases of the VAT pilot program and what it will mean for businesses in key sectors including financial services, insurance, real estate and construction. We will examine the impact the transition to VAT will have on pricing, overall indirect tax liabilities, changes to contracts, invoicing and IT systems and processes.”
  • Transforming Tax Reporting to Gain Efficiencies Recorded: Dec 3 2013 51 mins
    Ralph Cunningham- International Tax Review, Pierre Forster and Charlotte Johnson - Longview Solutions, Samantha Peggram - ITG
    With ever increasing pressures to seek efficiencies in day-to-day processes and increase time for planning and analysis, tax is looking to automate with tax technology. Imperial Tobacco worked with Longview Tax to implement a global data consolidation and reporting solution many years ago and continue to use it today. Learn about the technology, the implementation and the best practices for designing and implementing a solution.
  • Navigating Change: The Dynamic Environment for Intellectual Property Planning Recorded: Sep 10 2013 87 mins
    Ralph Cunningham - International Tax Review with David Cordova, Arin Mitra, Keith Reams and Tim Tuerff from Deloitte LLP
    Navigating Change: The Dynamic Environment for Intellectual Property Planning in association with Deloitte
  • India Budget 2013 moving towards a fair and stable international tax system? Recorded: Feb 28 2013 80 mins
    Ralph Cunningham ITR, Heetesh Veera, Tax Partner, Ernst & Young India, Rajendra Nayak, Tax Partner, Ernst & Young India
    In the light of the announcements such as the Shome recommendations on GAAR, indirect transfers for bringing stability to taxation and an increased need for fiscal consolidation, expectations are high that the upcoming budget will be a positive, but responsible budget with fair and stable provisions.
    To find out whether India continues to be an attractive investment jurisdiction and how the provisions may impact global investors, join our expert panellists Rajendra Nayak and Heetesh Veera, Tax Partners Ernst & Young for this web seminar on budget day .
  • Fuelling Controversy: Transfer Pricing in Oil & Gas Industry Recorded: Dec 14 2012 103 mins
    Ralph Cunningham - International Tax Review, Randy Price - Deloitte, John Wells - Deloitte
    Please join this special ITR Webcast to gather key transfer pricing insights specific to the Oil and Gas Industry value chain. This dynamic presentation, led by Deloitte Tax LLP’s National Transfer Pricing Leaders of its Oil & Gas Industry, will cover three core areas:
    •A primer on the O&G industry segments (e.g. upstream, mid-stream, etc.), transfer pricing fundamentals, and transfer pricing issues specific to the O&G industry to broaden the general knowledge base of international tax and transfer pricing professionals
    •The rapidly expanding global shale/tight oil and shale gas play and highlight some of the transfer pricing issues inherent in these cross-border investments of oil companies.
    •Transfer pricing considerations of intragroup financing that highlights the challenges of pricing cross-border loans in this capital intensive industry.
    Given the complexity and variety of tax issues within this industry, this presentation should be the starting point rather than the finish line for all of your O&G Industry transfer pricing inquiries.
  • Operational transfer pricing: minimising risk and maximising tax savings in 2013 Recorded: Dec 5 2012 81 mins
    Ralph Cunningham, International Tax Review, Tracey Rossow, Thomson Reuters, Elizabeth Blatchford Ford Motor Company
    While many multinational corporations (MNCs) have informed, well-supported transfer pricing policies and tax compliance documentation, they are often challenged with the day-to-day financial implementation of their transfer pricing policy. Failure to properly address this challenge can result in large year-end adjustments, process inefficiencies and increased tax costs. With increased scrutiny and tighter transfer pricing regulations expected in 2013, how can MNCs efficiently manage their day-to-day transfer pricing implementation, increase pricing transparency, and ensure accounting integrity for their intercompany pricing year round?

    In this webcast, Thomson Reuters and Ford Motor Company transfer pricing experts will discuss these issues and provide best practice approaches to minimise risk and maximise tax savings in 2013. This informative session will cover:

    • Current challenges and trends in global transfer pricing
    • Best practices to effectively implement, monitor, and adjust intercompany prices year round and avoid large year-end true-ups
    • Leveraging technology to automate and streamline the transfer pricing process
    • The Ford Motor Company implementation success story
  • Contingency planning for a crisis in the Eurozone Recorded: Dec 4 2012 92 mins
    Ralph Cunningham. International Tax Review Managing Editor, David Gill, Ernst & Young LLP (UK)
    What if the unthinkable happened and one or more countries left the Eurozone?

    Join us as we trace the footsteps of three hypothetical multinationals, who illustrate very different attitudes toward Euro exit contingency planning and are in different states of 'preparedness.' We will examine the potential impact on their supply chains, financial and legal structure and resulting tax consequences.

    By comparing and contrasting their experiences, we expect to learn some key lessons and actions tax directors could undertake now to avoid expensive tax mistakes in the future.

    Our moderator, David Gill, will chair the discussion between a panel of Ernst & Young professionals. Helmar Klink and Spyros Kaminaris will look at international tax implications; Craig Mitchell will focus on the supply chain; Mark Minihane will examine the treasury implications, and Cornelius Grossman will look at the legal perspective.
    Presenters:
    David Gill, Ernst & Young LLP (UK)
    Helmar Klink (Ernst & Young Belastingadviseurs)
    Spyros Kaminaris (Ernst & Young Business Advisory Solutions S.A)
    Craig Mitchell (Ernst & Young AG)
    Mark Minihane, Ernst & Young LLP(UK)
    Cornelius Grossman, Ernst & Young GmbH Wpg
  • Navigating Indian APAs Recorded: Aug 8 2012 80 mins
    Ralph Cunningham, International Tax Review, Vijay Iyer, partner and national leader, transfer pricing group, Ernst & Young
    A proactive approach to managing global transfer pricing disputes can enhance both efficiency and effectiveness. Many countries are therefore adopting advance pricing agreements (APA) programs as a way of addressing evolving transfer pricing issues worldwide — as of July 2012, more than 30 countries allow APAs.
    One jurisdiction with the highest rate of transfer pricing litigation activity is India, where a high proportion of taxpayers rely on litigation for resolution of disputes. One obvious reason for this could be the absence of an APA program in India under the current tax law. Realising the severity of the issue, an APA program has been implemented through the last budget amendments.
    The webcast will be discussing on APA process, best practices in framing an APA mechanism and update on the recent development in India
  • Negative List of Services - key Challenges in India Recorded: Apr 4 2012 116 mins
    Ralph Cunningham, International Tax Review, Rohan Shah, Managing Partner, ELP, Rohit Jain, ELP, Nishant Shah, ELP
    The Finance Bill 2012 reinvented the law on service tax by introducing the concept of Negative List Taxation. This proposed amendment, will have a deep impact on service transactions. The concept will cover all services (unless specifically excluded), thereby making most service providers liable to service tax. This new scheme has thrown up a range of new issues, which every business (whether a manufacturer, a service provider or a trader) will need to deal with. And the introduction of the Negative List, before the introduction of GST, leads to significant gaps in relation to generation and use of tax credits. This anomaly will, doubtless, add to the real indirect tax cost of transactions in India.

    This webinar is aimed at familiarising taxpayers with the new scheme and to highlight various issues and potential challenges that companies may face the future.
  • Indian Budget 2012 - The tax measures unveiled Recorded: Mar 16 2012 89 mins
    Ralph Cunningham, International Tax Review, Pranav Sayta, Ernst & Young, Harishanker Subramaniam, Ernst & Young,
    The Indian Budget announcement on March 16 provides an opportunity for the government to give clarity to domestic and international taxpayers on a range of key policies, such as the progress of direct and indirect tax reform. Will the Direct Taxes Code still be implemented from April 1 this year? Or will the government postpone it but extract key provisions such as advance pricing agreements and place of effective management and put them in place now? And what is the government’s thinking on the Supreme Court’s Vodafone decision? Will it introduce legislation to tax similar transactions?

    In this web seminar, Ernst & Young specialists and guests will give the insight you need on these issues and the others that will arise in the budget announcement.

    Speakers from Ernst & Young India will be joined by Dr. D.K. Srivastava, Director, Madras School of Economics, Chennai
  • Vodafone decision explained Recorded: Jan 24 2012 99 mins
    Ralph Cunningham, International Tax Review, Pranav Sayta, Ernst & Young, James Tobin Ernst & Young
    The Supreme Court, the apex court of India, has given its judgment in the Vodafone case covering the taxability of offshore transactions when shares of an overseas company directly or indirectly holding shares of/interests in an Indian company are transferred.

    This web seminar will analyse the key points that taxpayers should take from the decision, discuss the effect of the ruling on similar situations in dispute at the moment and highlight the options for companies faced with decisions about these sorts of transactions in the future.

    The web seminar will be followed by a Q&A where you will have the opportunity to ask questions of leading Indian tax specialists who deal with these issues every day.
  • Transfer pricing issues surrounding marketing intangibles - Indian perspective Recorded: Dec 15 2011 124 mins
    Rohan Shah ELP, Ajit Tolani ELP, Ralph Cunningham ITR,
    It is uniformly accepted that transfer pricing in India is becoming more and more complex. The tax authorities there often take stands on transfer pricing treatment, especially of marketing intangibles, that are diverse and aggressive, compared to jurisdictions in other parts of Asia and the rest of the world.
    In this webinar, experts from Economic Laws Practice and their guests from international law and consulting firms in the US, UK and the Netherlands will discuss some of the recent judicial rulings on marketing intangibles in India and best practice approaches that can be adopted by taxpayers.

    Speakers include: Rohan Shah ELP, Ajit Tolani ELP, Marc Levey Baker & McKenzie, Murray Clayson Freshfields Bruckhause Deringer, Steef Huibregtse Transfer Pricing Associates, Steven Carey Transfer Pricing Associates
  • Permanent establishment best practices in India Recorded: Oct 13 2011 101 mins
    Rahul K Mitra, PwC, Ajay Kumar, PwC, Ralph Cunningham ITR
    The attribution of profits to permanent establishments (PEs) is gaining complexity in India, with the Indian tax authorities often taking diverse and aggressive stand on attribution approach. This has resulted in significant tax litigation in India culminating in varied judicial precedents.

    Though India has a comprehensive tax treaty network and transfer pricing regulations based on OECD framework, unfortunately the close connection between PE attribution and transfer pricing has not been clarified in judicial rulings in the past, up until very recently when a Tax Tribunal emphasised the need to have a transfer pricing analysis for profit attribution purpose. At the same time, due to lack of concrete administrative or procedural guidance, India’s tax authorities are reluctant or hesitant to consider PE attribution issues based on transfer pricing fundamentals. This results in significant tax risks for taxpayers on account of PE exposure in India.

    In this webcast, experts from PwC will discuss some of the recent judicial rulings in India on this issue and best practice approaches that can be adopted by taxpayers to deal with the issue of attribution of profits to PEs.

    PwC Speakers: Rahul K Mitra (Executive Director and National Leader - Transfer Pricing) and Ajay Kumar (Executive Director and National Leader - Tax Markets)
    International Tax Review: Ralph Cunningham
  • Foreign Direct Investment Guidelines on LLPs Recorded: Jun 3 2011 67 mins
    Dinesh Kanabar KPMG, Hitesh Gajaria KPMG, Jack Grocott ITR
    The Government has just announced guidelines which will prompt almost all foreign investors to relook at their structure in India, given that LLPs are more tax efficient and flexible.
  • Insights into the India Budget 2011 Recorded: Mar 2 2011 93 mins
    Ralph Cunningham - ITR, and Partners of BMR Advisors
    Will the Indian government make changes to the direct tax regime to align it with the upcoming Direct Taxes Code (DTC)? What are the preparatory steps for aligning central indirect tax laws with the proposed GST model? Will inflation trends prompt the government to turn populist in Budget 2011? Can we expect big-bang tax reforms from the Indian government?

    Follow BMR’s leading tax experts for an in-depth analysis of the budget proposals in a budget seminar organised by BMR in association with the International Tax Review

    Speakers include: Mukesh Butani, Partner, BMR Advisors, Rajeev Dimri, Partner, BMR Advisors
  • Chapter 4 of the FATCA: Implementation Issues, Q&A Recorded: Dec 16 2010 92 mins
    Ralph Cunningham - ITR, Partners of DLA Piper and the Department of the Treasury
    Panel
    Aileen Barry, Director, National Tax Investigations, DLA Piper
    Alan Granwell, Partner, International Tax, DLA Piper
    Michael H. Plowgian, Attorney-Advisor in the Office of the International Tax Counsel at the US Department of the Treasury
    Brendan Fox, Tax Manager, Lloyds Banking Group
  • Taxation of carried interests Recorded: Jul 28 2010 125 mins
    Ralph Cunningham
    The U.S. Senate is currently debating a bill, the American Jobs and Closing Tax Loopholes Act of 2010 (H.R. 4213), which includes provisions that would tax carried interests as ordinary income.
Live webcasts focuses on matters within International Corporate Tax
Up-to-date analysis and comment on International Corporate Tax matters

Embed in website or blog

Successfully added emails: 0
Remove all
  • Title: Navigating Indian APAs
  • Live at: Aug 8 2012 4:00 pm
  • Presented by: Ralph Cunningham, International Tax Review, Vijay Iyer, partner and national leader, transfer pricing group, Ernst & Young
  • From:
Your email has been sent.
or close
You must be logged in to email this