What is included in the fee for T1134 foreign affiliate reporting?
The foreign affiliate return with a full set of schedules per affiliate, restated onto the basis the return requires rather than the basis the local accounts use.
What would make T1134 foreign affiliate reporting cost more than the standard tier?
The number of affiliates and the tiers between them. Work scales with entity count, not with revenue, and lower-tier affiliates each need their own reporting.
Is the fee really fixed?
Yes, for the scope quoted. If the scope changes — another year appears, an entity turns up, a certificate becomes necessary — we re-quote before doing the work, so there is never an invoice you have not already agreed to.
Does a dormant foreign affiliate still need a T1134 filed for it?
Generally yes, though a simplified version of the form is often available for a genuinely dormant or inactive affiliate — dormancy reduces the complexity of what needs to be reported, but it does not by itself remove the filing obligation.
How does a chain of foreign affiliates held through each other affect the T1134 filing?
Each affiliate in the chain typically needs its own reporting, since the form captures information at the level of the individual foreign affiliate rather than a single consolidated figure for the whole chain, which multiplies the preparation work relative to a single standalone affiliate.
What information does an active foreign affiliate's T1134 filing actually require?
Surplus and earnings computations, along with details of the affiliate's activities and its relationship to the Canadian filer, are the core of an active affiliate's filing, which is considerably more involved than the simplified reporting available for a dormant one.
Does T1134 filing frequency depend on the affiliate's size or activity level?
The filing is generally required on the same recurring basis regardless of the affiliate's size, though the level of detail required within the filing can vary depending on whether the affiliate is active, dormant or falls into another specific category the form recognises.
What is OECD Pillar Two?
A global minimum effective tax for large multinational groups, delivered through top-up taxes rather than a single global rate. Where a group's effective rate in a jurisdiction falls below the agreed minimum, the shortfall is collected — by the parent jurisdiction under the income inclusion rule, by the source jurisdiction under a domestic top-up, or as a backstop by other jurisdictions. Canada has enacted implementing legislation. The compliance burden is data, long before it is tax. See BEPS and Pillar Two.
Does a remote employee create a permanent establishment?
It can. One employee working from home in another country may be enough where the arrangement gives the company a fixed place at its disposal, or where that person habitually concludes contracts. Seniority and function matter more than headcount: a salesperson closing deals is a far greater risk than a developer. The exposure is corporate tax and payroll registration in that country, which is why it is worth testing before the hire rather than after. See PE risk review.
