Consultant · Transfer Pricing · Legal Quotient Consultants
Choosing the method, and defending it
Shreya Jain is a transfer pricing expert at Legal Quotient Consultants. Every intercompany price rests on a method — comparable uncontrolled price, cost plus, resale price, transactional net margin or profit split — and the method has to fit the transaction rather than the result anyone would like.
Her work is choosing that method, testing it against the comparables, and keeping the file current year by year, so that the policy a group adopted is still the policy its numbers show when a tax authority asks.
- Transfer pricing
- Method selection
Areas of expertise
Method selection
Choosing among the recognised transfer pricing methods, and recording why.
Annual updates
Keeping comparables and results current year by year.
Audit support
Answering an examination from the file already in place.
What Shreya handles
Method selection
which of the recognised methods fits a given transaction, and why the others were rejected.
Annual updates
refreshing comparables and results so the documentation matches the year it is filed for.
Year-end adjustments
bringing the actual results back into the range before the books close.
Audit support
answering a transfer pricing examination from the documents already on file.
Who Shreya works with
Multinational groups
Groups with related companies in two or more countries that need a pricing policy and the file to support it.
Indian and Canadian subsidiaries
Local companies owned from abroad, where the intercompany charges are the first thing a tax officer asks about.
Businesses facing a transfer pricing review
Companies answering a tax authority's questions about prices already charged.
Disclosures
Scope. This practice prepares and files tax returns and supporting documentation, and represents clients with the revenue authorities. It does not perform audit or assurance engagements.
General information. Nothing on this page is advice for a particular situation. Book a consultation and the position is worked out on the facts of your file, with the fee agreed in writing before any work starts. Call +1 (416) 619-0068.
Profile last reviewed September 2026.
Files that look like this one
The Local File That Has to Match the Accounts
A local file describes the entity's own controlled transactions and ties them to its statutory figures. Where the two do not reconcile, that is what an examiner opens with.
Read how this one runsIndian Transfer Pricing Certification With a Hard Deadline
An Indian entity with international related-party transactions needs an accountant's report filed by a date of its own, ahead of the return. The work is reconciling the transactions to the books first, because the report is only as defensible as that reconciliation.
Read how this one runsDocumentation Built to the US Standard
The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.
Read how this one runsWhether Documentation Was Required At All
The obligation turns on the transactions that actually happened rather than on the size of the group, and the penalty for contemporaneous documentation is charged by reference to the adjustment. The review establishes which side of the line the company sits.
Read how this one runsAn Indian Company Paying a Foreign Supplier
Payments abroad carry deduction at source and a certification filed before the money moves. Whether the treaty reduces the rate depends on what is being bought, and the classification is the decision the whole filing rests on.
Read how this one runsA Residency Determination Review After Leaving the Country
Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.
Read how this one runsA US Filer Married to Someone Outside the System
Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.
Read how this one runsPaying a Dividend Up to a Foreign Parent
The withholding rate depends on the treaty, on the size of the holding, and on whether the parent is the beneficial owner rather than a conduit. Establishing all three before the payment is what secures the lower rate at source.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
