India

Deloitte India

7th Floor, Building 10

Tower B DLF Cyber City Complex

DLF City Phase II

Gurgaon – 122 022, Haryana

India

Tel: +91 124 679 2901

Email: rajivanand@deloitte.com

Rajiv Anand is a corporate tax partner in the global business tax practice of Deloitte Haskins & Sells LLP (Deloitte India). He has more than 24 years of experience in domestic and international corporate taxation matters including cross-border restructurings and legal interpretations, and can help his clients with in-depth analysis and strategic planning. Rajiv has significant experience dealing with various domestic and international organisations in relation to handling and assisting with their assessments and appellate matters.

The core areas of Rajiv's experience include due diligence and international tax restructurings, in-depth analysis and strategic planning for inbound investments, and double taxation avoidance agreements (DTAAs) and exchange control regulations connected with complex cross-border transactions. Rajiv advises clients on various regulatory and tax aspects of doing business with/in India; dealing with domestic and international multinationals in relation to handling their assessments, and appellate proceedings including court proceedings.

Rajiv's work also includes analysing the constitutional validity of retrospective amendments and advising clients on the same, as well as providing day-to-day advisory and compliance support to multinational clients.

Rajiv is a member of the Institute of Chartered Accountants of India (ICAI) and the Institute of Cost and Works Accountants of India (ICWAI).

Deloitte India

Indiabulls Finance Centre

Tower 3, 27th-32nd Floor,

Senapati Bapat Marg, Elphinstone Road (W)

Mumbai, Maharashtra 400013

India

Tel: +91 22 6185 4288

Email: manishagupta@deloitte.com

Manisha Gupta is a partner of the Deloitte Haskins & Sells LLP (Deloitte India) transfer pricing practice. She has more than 15 years of experience in the fields of transfer pricing and international tax and has anchored some key transfer pricing litigation in India.

Since joining Deloitte India, Manisha has assisted leading Indian and foreign multinational companies to manage and resolve contentious transfer pricing controversy issues. She has also conducted a number of transfer pricing projects in a variety of industries (such as pharmaceutical, infrastructure, FMCG, software and ITeS, hospitality, logistics and more) involving audit defence, MAPs, APAs as well as planning and documentation studies. These have addressed a wide range of transfer pricing issues such as financial transactions including guarantees, intangibles, and characterisation, among others.

Manisha is a frequent speaker on transfer pricing topics and has authored and co-authored various articles on transfer pricing controversies, alternate dispute resolution, and other topics. She is a member of the Institute of Chartered Accountants of India and has previously worked with EY and KPMG.

Krishnomics Legal

N-117 (LGF)

Panchsheel Park

New Delhi-110 017

India

Tel: +91 11 65092194

Email: gagan@krishnomicslegal.in

Website: www.krishnomicslegal.in

Gagan Kumar is a commerce graduate from Delhi University and a member of the Bar Council of Delhi, as well as a fellow member of Institute of Chartered Accountants of India.

Before setting up Krishnomics Legal, Gagan was principal associate with one of the largest law firms of India. Gagan has also worked with Big 4 accounting firms and brings with him more than 17 years of experience.

He has extensive experience in litigation and advisory aspects of the tax practice. He has successfully represented various corporates before the Supreme Court, High Court and Income Tax Appellate Tribunal (ITAT) and Commissioner of Income Tax (Appeals), Dispute Resolution Panel of Income Tax, Central Excise & Service Tax Appellate Tribunal, National Consumer Dispute Redressal Commission, among others.

Gagan has been recognised as India's leading corporate tax lawyer by Who's Who Legal in 2012 and as a tax controversy leader by International Tax Review in 2013 and 2014.

He has been a regular speaker at various national and international forums. Gagan is a member of the Delhi High Court Bar Association and of the American Bar Association.

He has contributed various articles to national and international journals.

Over the years, Gagan has advised a number of domestic and international companies on tax issues relating to corporate tax, transfer pricing, mergers and restructurings, value added tax (VAT), central excise, customs, service tax and others. He has also advised on structuring options to various private equity funds.

Gagan has advised many not-for-profit organisations from a tax and regulatory laws perspective including compliance with the Foreign Contribution Regulations Act. He has advised leading multinational charities functioning in India. He is actively associated with platforms helping not-for-profit organisations on a pro bono basis.

KPMG India

8th Floor, Building 10-B

DLF Cyber City

Phase II?Gurgaon 122002

India

Mobile: + 91 98300 55281

Email: rkmitra@kpmg.com

Website: www.kpmg.com/in

Rahul Mitra is the national leader of dispute resolution and litigation in the fields of transfer pricing and international taxation for KPMG India. Rahul is a chartered accountant and an honours graduate in commerce.

Before joining KPMG India, Rahul was the national leader of PwC India's transfer pricing practice between 2010 and 2014. Rahul was a partner in the tax and regulatory services practice of PwC India between April 1999 and February 2015.

Rahul has more than 22 years of experience in handling taxation & regulatory matters in India. He specialises in transfer pricing, particularly inbound and outbound planning assignments; supply chain management projects; profit attribution to permanent establishments, among other areas.

Rahul independently handles litigation for top companies at the level of the Income Tax Tribunals. Some of the major wins for Rahul before the tax tribunals in transfer pricing matters are in the following cases, setting precedents, both in India and globally :

• BMW India: on marketing intangibles in the case of distributors;

• GAP India: on the remuneration model for procurement services, addressing Berry Ratio and location savings issues;

• Global One India: on accepting the residual profit split method & distinguishing it from the comparable profit split method;

• Schefenacker Motherson: on the concept of 'cash profit' to sales as profit level indicator;

• Cheil Communications: on the concept of 'pass-through cost' for intermediary companies;

• Development Consultants: on the concept of 'tested party' as least complex of two transacting entities; foreign related parties accepted as tested parties for first time in India;

• Fulford India: on the concept of 'value added distributor' for secondary manufacturers in pharmaceutical sector.

• ITC Infotech: on the concept and treatment of business models for agency and distribution of services.

In his personal capacity, Rahul has handled several APAs in India, involving clients from across various industries; and also covering complex transactions including non-integrated principal structures; contract R&D service provider models; distribution models, with related marketing intangible issues; financial transactions; and profit split models for royalties, among others.

Rahul is a member of the global editorial board of Transfer Pricing Forum, published by Bloomberg BNA. Rahul was the country reporter on the topic, 'Non-discrimination in international tax matters' for the IFA Congress held in Brussels in 2008.

Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries' perspective on APAs.

Khaitan & Co

One Indiabulls Centre

13th Floor, Tower 1

841 Senapati Bapat Marg,

Mumbai 400 013

India

Tel: +91 22 6636 5000

Fax: +91 22 6636 5050

Email: sanjay.sanghvi@khaitanco.com

Website: www.khaitanco.com

Sanjay is a chartered accountant and a lawyer with 20 years of professional experience in advising and helping clients on domestic and international taxation matters across various sectors of the economy including M&A transactions, transfer pricing, advising on and handling large tax litigations and high end representation before the tax authorities.

Sanjay's core competency is advising on both domestic and cross-border taxation and advising and representing in high end tax representation and tax litigation matters of Indian companies and multinational companies right up to the Supreme Court of India and before the Authority for Advance Rulings. He is a versatile tax professional with varied experience advising and representing before the courts and tax authorities. Clients value Sanjay for his sound and comprehensive legal tax counselling and the ability to handle tax matters before tax authorities and courts in India in a timely manner. His extensive experience both in (M&A) transaction advisory as well as in tax litigation gives him a unique edge in as much as he is able to provide guidance to clients from a preventative standpoint, ensuring that the tax advice in transactions is geared to prevent unnecessary litigation with the tax authorities in future.

Before joining Khaitan & Co, Sanjay worked with PwC, Arthur Anderson and RSM & Co and extensively advised clients on corporate taxation, cross-border transactions and on tax litigation matters. Sanjay has assisted Mr Dinesh Vyas, senior tax counsel at the Supreme Court of India in revising the renowned commentary on Income-tax law authored by legal luminary, the late Mr Nani Palkhivala (ninth edition). Sanjay has authored numerous tax articles in various Indian and international tax journals of repute including International Tax Review, IBFD Asia Pacific Tax Bulletin, and others. Sanjay is also regularly quoted in leading business newspapers on important tax rulings and other tax policy related developments in India. His timely and impactful comments and insights on significant tax matters and government tax policies are quoted by leading business journals in India including Business India.

Sanjay has been nominated as one of the leading tax advisers by Euromoney's Guide to the World's Leading Tax Advisers 2014 and acknowledged by Asialaw as one of the prominent taxation lawyers for the years 2011, 2012 and 2013.

Deloitte India

Deloitte Centre

Anchorage II

100/2, Richmond Road

Bangalore, Karnataka 560025

India

Tel: +91 80 6627 6105

Mobile: +91 98452 04631

Email: krsekar@deloitte.com

Website: www.deloitte.com

KR Sekar is a tax partner with Deloitte India and and co-leads the global business tax practice for Deloitte India. Sekar has more than 25 years of experience in the field of direct taxes, mergers & acquisitions, international taxation and transfer pricing. His client portfolio includes leading companies in technology, media, telecommunications (TMT), manufacturing and engineering.

Sekar's key areas of expertise include inbound structuring, litigation support and advising on cross-border tax issues. He advises inbound global companies coming into India on entry strategy and inbound structuring, and assists them on mitigating tax risks. He is also associated with many landmark litigation cases for global companies.

In addition to advising clients, Sekar is active in representing before the Government various tax issues impacting industry through his position in the Chambers of Commerce. He is also a prolific writer, contributing regularly to tax journals and tax coverage in the mainstream press. He has authored many books including Transfer Pricing Law & Practice, Taxation of Merger, De-merger & Foreign Collaboration and Landmark Judgements of Supreme Court on Direct Tax Laws: An Analysis.

Sekar is the chairman of the Direct Taxes Expert Committee, Bangalore Chamber of Industry & Commerce, is a member of the India Board of International Fiscal Association and also works closely with other chambers including the National Association of Software and Services Companies (NASSCOM).

Economic Laws Practice

1502 A Wing

Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Email: rohanshah@elp-in.com

Rohan Shah is the managing partner and leads the tax practice at Economic Laws Practice (ELP), a leading law firm in India.

Rohan received his law degree from the Government Law College of the Bombay University. After his LLB, he worked with Crawford Bayley and Co Advocates and Solicitors, Mumbai (1988-1989). In 2001, Rohan founded ELP which now has offices in Mumbai, Delhi, Pune, Ahmedabad, Bangalore and Chennai with a team in excess of 120 professionals.

Rohan is a qualified solicitor and, as a member of the Law Society of UK, is authorised to also practice in England and Wales. He is well known for his expertise in advisory, policy and controversy issues related to indirect taxes (excise, service tax, VAT and customs), domestic and international taxation in India. As a litigator, Rohan has successfully represented a wide spectrum of clients before the Hon'ble Supreme Court, various High Courts and the tribunals resulting in several reported judgments in the areas of customs laws, service tax laws, transfer pricing and other direct tax issues. Rohan has also deposed as a tax expert in various arbitration proceedings.

Rohan has been listed as a leading lawyer in India for his expertise in taxation and TMT practices by Asia Pacific Legal 500 and Chambers Asia-Pacific from 2009 to 2015; and by Asialaw Leading Lawyers 2013 & 2015. International Tax Review hailed him as being among the leading tax lawyers in the world, while Tax Directors Handbook recommended him from 2007 until 2013. He has also been selected among the 100 leading tax lawyers in the world by Who's Who Legal – Corporate Tax 2009, leading lawyer by Who's Who Legal – Corporate Tax 2010 to 2015 and Trade & Customs 2013 to 2015. He was also featured in the Asian Legal Business (ALB) Hot 100 in 2010 and India Today's, January 2000 edition as one of the '50 Indians for the Next Millennium'. He has been recognised as the exclusive winner of the Corporate Tax category in India in the Client Choice Awards 2014 & 2015.

Deloitte India

iPark, Plot 15, Phase IV, Gurgaon

Delhi, 07 122001

India

Tel: +91 124 679 2261

Email: spsingh@deloitte.com

SP Singh, Deloitte India, advises multinational corporations on international and domestic transfer pricing, encompassing documentation, planning, and controversy defence. SP is the chief negotiator for advance pricing agreements (APAs) and mutual agreement procedures (MAPs). He provides services to major multinational clients in a wide range of industries, including sourcing of apparel, software development, IT and ITeS, pharmaceutical, cosmetics, chemicals and energy. His clients are from various countries, including the US, the UK, Japan, Australia and France, apart from the Indian multinationals.

Before joining Deloitte India, SP was with the Indian Revenue Service for more than two decades. He held various positions in the service, including director of income tax (international taxation) and commissioner of income tax (appeals). He participated in the negotiation of tax treaties with more than 30 countries and took part in mutual agreement procedures (MAPs). He has represented India in several international conferences and presented papers. SP was a member of the Expert Group on Transfer Pricing constituted by the Ministry of Finance for drafting transfer pricing regulations. He also represented the Income Tax Department before the Authority for Advance Rulings in several cases.

SP has an MSc in fiscal studies from Bath University in the UK and has earned a master's degree in physics from India. He is a member of the Bar Counsel of Income Tax Appellate Tribunal and is a regular contriubutor at the National Academy of Direct Taxes (apex training institute for Indian Revenue Service), Institute of Chartered Accountants of India, International Fiscal Association, and Indian Institute of Management, Lucknow. He is co-chairman of the Direct Tax Committee of ASSOCHAM.

SP was included in the 2013 Euromoney Guide to the World's Leading Transfer Pricing Advisers. He has co-authored several white papers on TP related matters including APAs and safe harbour provisions, among others, and has co-authored two books on transfer pricing. He regularly contributes to international and national journals on taxation.

Economic Laws Practice

1502 A Wing

Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Email: nareshthacker@elp-in.com

Naresh Thacker is a litigation and dispute resolution partner specialising in tax and commercial disputes. He is a qualified lawyer with the additional attribute of being a solicitor in England and Wales.

Naresh has successfully represented clients in matters pertaining to economic offences before a range of tribunals and courts in India, including high courts across the country as well as the Hon'ble Supreme Court. He is sought after for his abilities to litigate complex issues of indirect tax (excise, service tax, VAT and customs).

Naresh is also actively involved in the field of alternate modes of dispute resolution and has managed a number of ICC, LCIA, SIAC, UNCITRAL, Swiss rules and ad-hoc arbitrations. He has been part of mediation and conciliatory proceedings at the behest of clients and has brought them to fruition.

Naresh is active in a number of professional organisations including The Law Society, UK, London Court of International Arbitration (LCIA) and the All India Federation of Tax Practitioners (AIFTP). He is often quoted by prestigious international journals and his articles continue to appear in trade publications around the world. He has recently been featured as an expert in World Tax 2015 and has been recommended for litigation in the RSG India Report 2015. The report quotes that he is praised by clients for having "great knowledge" of litigation.

Before joining ELP, Naresh practiced as an independent counsel on indirect tax and litigation matters.

Economic Laws Practice

801 A, 8th Floor

Konnectus Tower

Bhavbhuti Marg

Opp A Gate Railway Station

Near Minto Bridge

New Delhi-110 002

India

Tel: +91 11 4152 8400

Email: alokyadav@elp-in.com

Alok Yadav is a litigation and dispute resolution partner specialising in tax. He holds a law degree from Delhi University and is a member of the Supreme Court Bar Association.

Alok has more than 15 years of experience as a legal professional in the areas of direct and indirect tax litigation, having started his career as a lawyer with JB Dadachanji and Co, Delhi in 2000. After leaving JB Dadachanji and Co, he was associated with Lakshmikumaran & Sridharan Attorneys.

Alok's expertise spans across varied aspects of law including customs, central excise, service tax and litigation matters related to indirect taxes. He has appeared in more than 250 matters independently before the Supreme Court for clients such as PepsiCo, Hewlett Packard, Bharti Airtel, Cargill India, Nestlé India and Kelvinator Electrolux.