Transfer pricing materiality checker — free calculator
Measures your intercompany flows against the thresholds you enter, and flags where documentation is mandatory regardless of size.
- 15+Years of cross-border experience
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Measures your intercompany flows against the thresholds you enter, and flags where documentation is mandatory regardless of size.
Enter your figures
An estimate for planning only. Rates and thresholds used here are the assumptions stated on this page; we confirm every figure against the issuing authority for your own tax year before anything is filed.
How the estimate is built
Documentation requirements differ: some jurisdictions ask for contemporaneous records as a penalty-protection condition above a threshold, and others impose a mandatory certified report on any international related-party transaction. India is in the second group, which is why a single small intercompany charge there creates a filing. Confirm the specific threshold for the jurisdiction and year before relying on a result.
What to do next
A calculator narrows the range; it does not settle a filing. If that describes your position, the next step is a short call — not a form.
Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
US expat tax calculator — what this page covers
If you came here for US expat tax calculator, this is where it is dealt with. The subject is transfer pricing materiality checker, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.
Why choose Legal Quotient for transfer pricing materiality checker calculator
Filed with the authority, not just prepared
The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.
Cross-border is the whole practice
International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.
One team, not two firms billing separately
You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.
A named reviewer on every file
Every page on this site and every file we deliver says which practitioner reviewed it — a person, not a team inbox.
What these engagements turn on
Materiality tested separately for each side of the flow
A manufacturing group had assumed a single group-wide documentation policy answered for every subsidiary. Each leg of the intercompany flows was instead measured against the threshold in force in the jurisdiction that would ask the question, rather than against a consolidated group figure. Some entities sat below their local thresholds and others above. The engagement produced a per-entity position paper recording which regime each company was in, the figure it had been tested against and the source relied on for that figure, so the following year's test was a refresh rather than a fresh exercise.
One Indian service charge created a standing annual filing
A group set up a small Indian support company and charged a modest monthly service fee to the parent. The flows were immaterial in group terms and had not been treated as a transfer pricing matter at all. The work established that India's certified accountant report applies to international related-party transactions without a size test, documented the service actually performed, and set the charge on a stated basis. The engagement produced a benchmarking file and a repeatable annual calendar item running from the first intercompany invoice rather than from a threshold.
Intercompany funding balance pushed the group over its threshold
A holding company had advanced working capital to an operating subsidiary and treated it as internal funding rather than as a transaction. Goods and service flows had been totted up for the threshold test; the loan balance had not. Restating the test with the balance included moved the group above the line. The work covered the terms of the advance, the basis for the interest rate and whether an unrelated lender would have made it. It produced a written loan agreement, a pricing memorandum, and a corrected answer to the return's documentation question.
Royalty introduced mid-year without a licence behind it
An operating company began paying a licence fee to an affiliate holding the group's brand, on an instruction from the board and nothing in writing. The charge had run for part of the year before anyone asked what supported it. The work reconstructed what had been licensed, when the right had passed and what comparable arrangements looked like, then documented the basis for the rate applied. The engagement produced a signed licence, a contemporaneous pricing file for the part year, and a note of the flows to be included in the next annual test.
Documentation prepared in one country did not travel
A group held a full documentation file prepared for its parent jurisdiction and assumed it answered for the subsidiaries. The file described the group and its functions but tested no subsidiary's own transactions against its local requirement, and in one jurisdiction the mandatory report had no threshold to sit under in any event. The work mapped each entity's requirement against what the existing file actually contained, then filled the gaps locally. It produced local files that sit beneath the group document instead of being substituted for by it.
A restructuring that split flows without reducing the requirement
Flows had been routed through an additional entity, with the effect that no single company appeared to cross its threshold. The work tested whether the arrangement stood on its own terms, looking at what the intermediate company did, what risk it bore and what it would have been paid at arm's length, and separately whether the aggregation rules in each jurisdiction look at connected flows together. The engagement produced a written position on both questions and a recommendation that documentation be maintained on the basis the requirement still applied.
A Margin Defended With a Benchmarking Set That Fits the Facts
A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.
Read how this one runsMoving Money Out of India and the Certificates It Needs
A remittance out of India needs its tax position certified before the bank will process it. The file establishes the character of the funds, produces the certification, and keeps the position consistent with the returns already filed.
Read how this one runsAll case studies — every published engagement in one place.
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Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.
Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.
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