India

SR Dinodia & Co, Chartered Accountants

K-39 Connaught Circus

New Delhi – 110 001

India

Tel: +91 – 011- 4370 3300

Email: pallavidinodia@srdinodia.com

Website: www.srdinodia.com

Pallavi Dinodia is a partner at SR Dinodia & Co Chartered Accountants. The firm is one of the oldest in India and is ranked among the top 15 firms across the country.

Pallavi has had an outstanding career spanning the past 15 years. During the past decade she has specialised in transfer pricing and international taxation, gaining a reputation across India for her expertise in the field. She advises corporates, both domestic and foreign, helping them to fulfil their complex compliance requirements in India. In addition, she acts as a counsel, representing clients before quasi-judicial authorities and the Income Tax Appellate Tribunal (ITAT) in India on matters related to transfer pricing, dispute resolution, advance pricing arrangements and the avoidance of double taxation.

She has worked extensively with global businesses across Asia, the US and Europe on advisory and transactional work, including a stint at a financial services company in Zurich as an in-house counsel. She has combined her understanding of finance and accounting with her expertise across corporate and tax law to play a strategic role in high value transactions for her firm. Succession being mired with complexities, she advises large Indian business families, taking into account the aspirations of the new generation joining the business, and helps with putting structures in place which not only provide for smooth succession but are also tax efficient.

Pallavi has represented the Asian region as a board member on the international committee of one of the leading global alliances of independent auditing, tax, accounting and consulting firms. She is also an independent director on the board of a very large listed company.

Pallavi authored a best-seller Transfer Pricing Demystified published by Bharat Law House in 2013, which was the first book on the practical issues related to transfer pricing in India. Pallavi is regularly invited to speak at tax conferences and at various chambers of commerce such as the Federation of Indian Chambers of Commerce and Industry (FICCI) and the Confederation of Indian Industry (CII). She has been part of the various tax committees at the Institute of Chartered Accountants of India (ICAI) and has also spoken at numerous ICAI events on complex tax issues. She is also a regular contributor to industry publications.

Pallavi graduated with distinction in commerce (Hons) from Lady Shriram College, University of Delhi. She is a fellow member of the Institute of Chartered Accountants of India (ICAI). She also holds a law degree from the University of Delhi. She is a qualified information system auditor (DISA) as well as an ICAI certified international tax expert.

BMR & Associates

BMR House

36 B, Dr R K Shirodkar Marg

Parel, Mumbai 400 012

India

Tel: +91 22 6135 7170

Fax: +91 22 6135 7070

Email: shefali.goradia@bmradvisors.com

Shefali Goradia is a partner with BMR & Associates' corporate tax practice. She has more than 24 years of experience in international tax.

Shefali specialises in cross-border taxation. She advises multinational enterprises in designing global holding and operating structures, inbound and outbound investments, cross-border mergers, acquisitions and other corporate reorganisations. She works extensively with leading investment and private equity fund houses on developing and implementing domestic and international fund structures. She has advised banks in designing structured finance products. She advises several companies in the hospitality and pharmaceutical industries on taxation in India and IT companies on the taxability of software and e-commerce transactions. She has obtained private rulings for several clients.

Shefali is a regular writer and lecturer on international tax topics. She contributed the India chapter – "Is there a Permanent Establishment?" – to the 63rd IFA Congress, Vancouver, 2009. She was also appointed the co-general reporter for the IFA Congress held in Mumbai, India in 2014 on the topic: "Cross-border outsourcing – issues, strategies and solutions".

Shefali was voted one of the region's preeminent advisers for taxation in the 2011 Asialaw Leading Lawyers survey. She featured in the Guide to the World's Leading Banking, Finance and Transactional Lawyers 2012 as one of the outstanding practitioners in the field of investment funds and is listed in the International Who's Who of Corporate Tax Lawyers and the International Who's Who of Private Funds Lawyers consecutively from 2009 – 2014. She was recognised as among the eight best Indian tax advisers by Legal 500 and the Tax Directors Handbook 2009. Shefali represented India in Legal Media Group's Tax Advisers Expert Guide and was recognised as among the top 10 tax advisers in India in World Tax (2004 – 2006).

BMR & Associates

22nd Floor, Building No. 5

Tower A

DLF Cyber City, DLF Phase III

Gurgaon 122 002

India

Tel: +91 124 669 5055

Fax: +91 124 669 5001

Email: parul.jain@bmradvisors.com

Parul Jain is a partner with BMR & Associates' corporate tax practice in Gurgaon. She has more than 14 years of experience in international tax.

She has been advising Fortune 500 clients on various aspects of international taxation including globalisation, investment and divestment strategies, structuring of inbound and outbound investments, structuring of offshore and domestic funds, transfer pricing, taxation of e-commerce and employee stock options, among other areas. She also advises various clients with respect to the restructuring of their business operations, including advice on M&A transactions, spin offs and group reorganisation strategies. Parul has assisted a number of Indian and foreign clients on litigation matters involving international tax issues.

Some of her noted publications include Anti-Treaty Shopping Measures – OECD Report and the Indian Experience, CITC Compendium, 2012; A Primer on Tax Characterisation of Software Payments, Asia-Pacific Tax Bulletin, 2012; and The General Anti Avoidance Rule: An end to too much of a good thing?, International Taxation, Volume 5, September 2011.

She has presented at various seminars at the domestic and international level, at the American Bar Association (2007 and 2008), Assocham International Tax Conference (2007 and 2011), International Fiscal Association (IFA) International Tax Conference, Weekend Study Circle – South India Chapter (2010 and 2011), and IFA – Mauritius Branch 2nd Asia/Africa IFA Conference (2008). She conducts study circles for the IFA Delhi Chapter on a regular basis. In addition, Parul was involved in organising and speaking at the IFA YIN conference in Bangalore in 2010, and conducted a webinar on anti-avoidance Doctrines for the IFA India branch WIRC YIN study circle meeting in 2010. She has been nominated as the India branch reporter on "Taxation and Fundamental Rights: Taxpayers' Procedural Rights in a Globalised World" for the IFA 2015 Basel Congress. Parul has further been recognised by International Tax Review's World Tax 2013 guide for her work on a litigation matter involving the transfer of shares of an Indian group company. She has also been listed in the Legal 500 directory.

Parul is a graduate in commerce from the University of Delhi and a qualified chartered accountant. She is also an advocate and a member of the Delhi Bar Council.