Sangesh Sase

Sr. Executive at TransPrice Solutions LLP India

Areas of practice

  • Tax Planning
  • Tax Law

I can help with

(A) Transfer Pricing: 

1. Advisory and Planning 

• Transfer Pricing Policies 
• Inter- company Agreements 
• Group profit planning 
• Cost sharing arrangements 
• Structuring Intangibles 
• Domestic Transfer Pricing 
• On- call Advisory 

2. Compliance and Documentation: 

Preparation of Transfer Pricing Study Report including group overview, industry analysis, functional analysis and economic analysis 

3. Representations at tax offices including Transfer Pricing office and higher level judicial authorities including Tribunal, High Court and Supreme Court 

(B) International Taxation: 

• International holding company structures (branch, subsidiaries, JVs) 
• Tax effective investments and repatriation 
• Inbound and Outbound tax advisory 
• Optimizing withholding taxes 
• Structuring cross- border business models 
• Permanent Establishment reviews 
• Interpretation of Double Tax Avoidance Agreements (DTAA’s) and advisory

Sangesh's Activities

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Dear Members,

We are pleased to present TransPrice Times for the first fortnight of April 2017.

This periodical covers some key aspects from transfer pricing and international taxation, including rulings on foreign tax credit, royalties, benefit test and withholding taxes. For all the innovators, it is important to note the release of Form No. 3CFA for obtaining tax relief under patent box regime under S. 115BBF of the Income-tax Act 1961.

TransPrice Times - 1st - 15th April 2017
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Dear Members,

We are pleased to present TransPrice Times for the second fortnight of March 2017.

This periodical covers the important amendments made to Finance Bill 2017, which has now received the Presidential assent. In other recent updates, this issue covers the circular on Income Computation and Disclosure Standards (ICDS) released by CBDT, while the Tax Courts have delivered important rulings addressing key transfer pricing issues related to recharacterization of share application, depreciation adjustment.

TransPrice Times - 16th - 31st March 2017
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Dear Readers,

We are pleased to present TransPrice Times for the first fortnight of July 2016.  

In this bulletin, some key issues in Indian litigation have been discussed with regard to nature of foreign exchange fluctuations, selection of tested party for carrying out transfer pricing audit and method of benchmarking royalty transactions. Meanwhile on the international taxation front, OECD is keeping MNCs on its toes by releasing various discussion drafts on the work recommended under Action 4 (limiting interest deductions) and Action 7 (Preventing Artificial Avoidance of Permanent Establishment Status).

We hope you find this newsletter both timely and useful, and we look forward to your feedback and suggestions to improve it further. You can write to us at akshaykenkre@transprice.in

Happy Reading!!!

TransPrice Times - 1st - 15th July 2016
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Dear Readers,
 
We are pleased to present TransPrice Times for the second fortnight of June 2016.  

This issue contains diversity of case rulings ranging from issues on royalty / FTS to management service fees and TDS rates on payments made to a non-resident.

CBDT has been on a notification spree where in last 2 days, it has notified the foreign tax credit rules and the much awaited 'indirect transfer' rules which will be taken up extensively in the next bulletin along with the recent amendment on General anti-avoidance rules (GAAR).

We hope you find this newsletter both timely and useful, and we look forward to your feedback and suggestions to improve it further. You can write to us at akshaykenkre@transprice.in

TransPrice Times - 16th - 30th June 2016
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Dear Readers,

We are pleased to present TransPrice Times for the first fortnight of June 2016. 
 
In this bulletin, OECD continues to propose key inputs and seeks to incorporate major issues and amendments relating to Action 8-10 (Transfer Pricing), Action 13 (CbC reporting) and Action 15 (Multilateral Instruments) of the BEPS Project. 

Further, some key issues in the Indian litigation revolving around use of multiple year data, attribution of profits and marketing intangibles are addressed.
 
We hope you find this newsletter both timely and useful, and we look forward to your feedback and suggestions to improve it further.

TransPrice Times - 1st - 15th June 2016