Do I need local file?

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Answer

It sets out the entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results. The requirement usually turns on whether a transaction happened at all, not on how large it was.

Whether you need it

It sets out the entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results. Where the entity's actual margin sits outside the tested range, the file has to explain the difference before the auditor does.

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The carve-out

The local file is where the group's story meets the local entity's numbers, and it is the document a local auditor tests line by line.

Do I need local file?
ItemAmount
RevenueC$28,000,000
Operating margin reported2%
Operating profit reportedC$560,000
Assumed tested range3% – 7%
Profit at the bottom of the rangeC$840,000
Potential adjustmentC$280,000

A margin below the range invites an adjustment of C$280,000 in this jurisdiction — and unless the other country makes a corresponding adjustment, that profit is taxed twice. The documentation is what turns this into a conversation rather than an assessment.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

Where to go from here

The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on Local file. If that describes your position, the next step is a short call — not a form.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General guidance only. Your own facts decide the answer, so bring them to a call before relying on this.

International tax accountant — what this page covers

People reach this page searching for international tax accountant. It is covered here as it applies to local file — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

Cross-border tax case studies

Case study 1

Distributor margin below the tested range explained in the file

The local distributor had reported a margin under the range its comparables supported, for the second year running. Rather than adjust the result or ignore the gap, the work was finding the cause: a warehouse move and a lost key customer, both visible in the accounts. Work consisted of isolating those costs, testing the margin with and without them, and writing the explanation into the file with the ledger references attached. The engagement produced a documented reason for the position, prepared before any enquiry, and a note of what would evidence it if asked.

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Case study 2

Management fee paid to a parent documented as a controlled transaction

A monthly charge from the parent had been posted for years under a heading nobody in the local entity could explain. The file could not describe the transaction, so it could not price it. Work consisted of establishing which head-office functions the local entity actually drew on, who performed them, and how the amount had been arrived at. The engagement produced a functional description of the services received, a method selected on the basis of that description, and a written record of the basis on which the charge had been set.

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Case study 3

Loss year analysed before the file was written

The entity had made a loss and the group's instinct was to file the documentation unchanged and hope the year passed unnoticed. A loss is the result most likely to draw an enquiry, so the analysis was done first. Work consisted of separating the operating result from one-off items, testing whether the loss sat with the functions and risks the entity actually bore, and reviewing whether the method still fitted. The engagement produced a file that states the loss, explains what produced it, and shows why the pricing policy was not the cause.

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Case study 4

Local file rebuilt from the accounts after the preparer left

The previous file had been prepared externally and the working papers had not been handed over, so the comparable set and the adjustments behind the range could not be reproduced. Filing a document nobody could explain was the greater risk. Work consisted of rebuilding the analysis from the entity's own accounts and contracts, running a fresh search, and comparing the outcome with the earlier conclusion. The engagement produced a file with working papers retained in-house and a memorandum recording where the new analysis agreed with the old one and where it did not.

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Case study 5

Method selection revisited when the comparables no longer fitted

The entity's functions had shifted over several years from reselling to contract assembly, while the file carried forward the method and comparable set chosen for the earlier business. The result still fell inside the range, which had discouraged anyone from looking. Work consisted of redoing the functional analysis against current contracts and operations, then selecting the method that followed from it. The engagement produced a changed method with the reasoning documented, a comparable set matching the entity as it now operates, and a note explaining the change from the prior year.

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Case study 6

Two transaction streams separated into their own analyses

The entity both distributed finished goods and provided support services to affiliates, and a single combined margin had been tested against one range. The blend hid a distribution result at the bottom of its range behind a services result above its own. Work consisted of separating the revenue, costs and assets between the two streams, then analysing each against its own comparables. The engagement produced two documented transaction analyses in one file, with the allocation basis recorded, and a clear statement of where each stream's result sits.

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Case study 7

The Same Income Taxed Twice on Paper

Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.

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Case study 8

Inheriting Property in India While Living Abroad

India does not tax the inheritance itself, but the later sale and the money leaving the country both have positions of their own. The file establishes the cost base to use on that sale and what the remittance will require.

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All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.

Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Also asked about Local file

What has to go in a local file?

The entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results. Those five parts are not a checklist to be filled in separately, they are an argument: the functions and risks you describe should be the reason the method makes sense, and the method should be the reason those comparables are the right ones. A file where each section is individually defensible but the sections do not follow from one another is the version that reads badly to an auditor, because the join is where the questions start.

Our margin is below the tested range — what do we put in the file?

The explanation, and you want to be the one giving it. Where the entity's actual margin sits outside the tested range, the file has to explain the difference before the auditor does. That means identifying what caused it — a start-up period, an exceptional cost, a capacity problem, a customer loss — and evidencing that cause from the accounts rather than asserting it. A file that reports a result outside the range and says nothing about it has handed the first question of the audit to the other side, along with the silence that makes it look unanswerable.

Do we need a local file for a management fee we pay our parent?

A charge from a parent is a controlled transaction, so it belongs in the analysis whatever it is called. Management fee is a label rather than a description, and the work is establishing what was actually supplied, by whom, and on what basis the amount was set. That is what the functional analysis has to carry. The fees least likely to survive a review are the ones where nobody can say what service was received, because the file then has a method and comparables sitting on top of a transaction it has not described.

How old can our benchmarking study be?

The file has to be evidence about the year it covers. A range computed several years ago is evidence about those years, so carrying it forward unexamined leaves a gap between what the file claims and what it shows, and that gap widens as the comparable set ages, companies leave it and the market moves. The practical approach is to check each cycle whether the comparables still fit the entity being tested and whether their own results have moved, and to record that check. Refreshing the search is cheaper than explaining why you did not.

Can we just use the group master file instead of a local file?

No, because they answer different questions. The master file describes the group; the local file is where the group's story meets the local entity's numbers, and it is the document a local auditor tests line by line. The group description contains nothing about this entity's controlled transactions, comparables or results, so it cannot be tested against them. The two documents do need to agree with one another, and where a local file has to be written quickly the master file is the right place to start, but it is not a substitute.

What if an audit starts and we have no local file?

You then build the analysis under time pressure and with the auditor's questions setting the agenda, which is the expensive way round. The file's value is that it fixes the description of the entity's functions, the method and the comparables before anyone is arguing about the result. Prepared afterwards, the same analysis looks assembled to fit an answer, and any inconsistency with the group's own description is found by the person examining you. If an audit has opened, the order of work matters: establish what is being asked, then document.

Can you give a plain transfer pricing example?

A Canadian company manufactures at a cost of one hundred and its US subsidiary sells to customers for one hundred and eighty. If the parent invoices the subsidiary at one hundred and ten, most of the margin is taxed in the United States; invoice at one hundred and seventy and most of it is taxed in Canada. Nothing about the business changed — only which treasury collects. That is why the arm's length price, the one unrelated parties would have agreed, is the reference point both authorities use. See our transfer pricing work.

Is "fund transfer pricing" the same thing as transfer pricing?

No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.

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Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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