Nitin Seth

Team – Global Tax Advisory Services (GTAS) Key Assignments • Corp Tax Returns – Review of audited financials, tax audit reports etc. to prepare Corp Tax Returns for various clients • Corp Tax Audits - Verification of information received from clients, preparing detailed submissions to be filed before IRS, managing tax audits independently till completion. • Corp Tax Appeals - Analyses of various adjustments made in tax audit, filing of appeals, technical research on relevant issues, collating more factual information which can help in defending the appeal, preparing submissions and appearing before appellate authorities. Working with senior tax partners and also legal counsels for appeals before Tribunal, High Court and Supreme Court. • International Tax – Analyses of various cross-border transactions from the perspective of Royalty, Technical Services and Permanent Establishment as per tax treaties. Preparing and finalizing tax opinions given to various clients. • Tax Provision, Deferred Tax and Contingent Liabilities for Indian listed companies. Key Clients – American Express, Ravva Oil, Indo Rama, Modi Group, Philip Morris Promotions – Joined as Tax Executive in Mar 2001 and promoted to Senior Tax Executive in Apr 2004

Nature of Business – R&D relating to microprocessor and chipsets, Marketing and other Support Services to Intel group Key Role & Responsibility • Corp Tax Returns – Review of audited financials, preparation and filing of Corp Tax Returns • Tax Audits and Appeals – identifying potential challenges, strategic planning to manage them in advance, strong partnership with finance teams, collating information, co-ordinating with consultants and attending hearings before Tax and Appellate Authorities • Expat Tax – Tax filings of India Inbound and Outbound assignee through consultants. Worked as project leader to review global expat policy and inter-co charges • Transfer Pricing (TP) – conducting functional interviews with key personnel, finalizing TP documentation of India, managing TP audits, appeals and MAP applications. Worked with global TP team for TP compliances of Taiwan, Malaysia, Vietnam and Thailand. Preparation and filing of APA Application, planning and managing onsite verification by Indian IRS. Responding to queries raised in APA relating to FAR etc. • International Tax – Analyses of various cross-border transactions in R&D of Technology business from the perspective of Royalty, Technical Services and Permanent Establishment as per tax treaties. Seeking tax opinions and deciding tax position to be adopted. Strong partnership with accounting team w.r.t. withholding tax on cross-border remittances • Merger and Acquisitions (M&A) – Worked as part of global M&A team from tax perspective which included understanding critical requirements, identifying probable tax issues, examining possible options of acquisition in India, closely working with various stakeholders and be part of strategic planning and decisions during pre-acquisition Promotions – Joined as Tax Specialist in Jan 2007 and promoted to Tax Manager in Apr 2011

Nature of Business - Sale of Advertising Space on its website and also Software Development activities Key Role & Responsibility • E-Commerce – build strong business acumen w.r.t. e-commerce transactions, location of IP, Servers, working of Web-Portal etc. Identify potential tax risk, technical research into various issues, seeking opinion from tax counsel, analyzing global tax impact and deciding tax positions. • Transfer Pricing (TP) – review of TP policy, conducting functional interviews with key personnel, drafting inter-co agreements, preparing segmental financials, finalizing TP documentation of India and Hong Kong with Consultants, managing TP audits, appeals and MAP applications. • International Tax–Analyzing various transactions in website business from the perspective of Royalty, Technical Services and Permanent Establishment as per tax treaties. Seeking tax opinions and deciding tax position to be adopted. • Funds Repatriation – Identified various possible options for remittance of surplus funds to HQ with minimal tax cost – redemption of Preference Shares and Buy-Back. Repatriation in case of loss making business through Capital Reduction (end to end) – feasibility study, filing of application before High Court, valuation of business, attending court hearings, obtain court approval and RBI compliances. • Corp Tax – Finalizing Tax Returns, managing tax audit and appeals • Service Tax – Filing of Tax Returns, managing audits and investigations. Seeking opinions from tax counsel w.r.t. taxability of new services, i.e., online digital advertising as they were initially not subject to tax. • Goods and Service Tax (GST) – GST Impact analysis, transition of tax credits into GST regime, planning for implementation of new tax code, coordinating with teams in ERP, Accounts Payable and Receivable. • US Tax Reserves – computing tax reserves to be created for India and Hong Kong as per US FIN 48 and FAS 5 Promotions – Joined as Senior Tax Manager in Jan 2014 and promoted to Tax Director in Apr 2017

Nature of Business – Manufacturing of Metro Rail products like AC, Disc Brakes, Pantograph, Couplers Key Role & Responsibility • Goods and Service Tax (GST) – Implementation of new tax code, decide tax position in various transactions and complex scenarios. Build processes to generate data from ERP in desired formats which would help in filing GST returns. Work across functions to minimize tax impact arising due to “Inverted Duty Structure”. Preparation and filing of GST Returns for all locations in India. • Excise Duty – Managing onsite audits, collating necessary information, defending HSN classification and applicable rates of duty. • Corp Tax and TP – Filing of Corporate Tax Return, finalizing Transfer Pricing documentation and certification, coordinating with HQ and Consultants for filing of Master File as per Indian TP laws.

Nature of Business – Trading of Petrol, Diesel and Oils Key Role & Responsibility - Leading tax team of 20 people (approx.) for preparation and filing Tax Returns of GST, Corporate Tax, supporting Tax Audits and Appeals, managing Global Tax processes and controls and people management.

Nature of Business – Professional Services Team – E&Y Finance / Internal Tax