Customs valuation vs transfer price — reasonably priced, fixed fee

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Customs and income tax test the same intercompany price with opposite incentives, and satisfying one does not evidence the other. Ask us about reasonably priced customs valuation vs transfer price: call the 24-hour helpline on +1 (416) 619-0068, or request a written fixed quote today.

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  • 15+Years of the founder's cross-border experience
  • 18,000+Clients served across our offices in India, the USA, Canada and the UAE
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
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Secure a fixed quote

Start by sending whatever paperwork exists — a written fixed quote comes back before any work begins.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • Google rating 5.0 out of 5
  • 18,000+ clients served
The short answer

Customs and income tax test the same intercompany price with opposite incentives, and satisfying one does not evidence the other. Customs valuation methods and transfer-pricing methods overlap but are not identical, and related-party transactions attract scrutiny under both.

Who this applies to

  • You sell goods or digital services into another country
  • Stock is held in a country where you have no entity
  • A marketplace collects some taxes and leaves you the rest
  • You have never tested a registration threshold by destination
  • A customer has asked for a tax number you do not have

That list is deliberately concrete. If you recognise yourself in it, this page is the right starting point; if you do not, tell us and we will point you elsewhere without charging for it.

Two of the firm’s advisers at the glass desk in the Delhi office

Transparent, fixed pricing for Customs valuation vs transfer price

Reconciling customs valuation with a transfer price is priced on how many import streams and related-party product lines are in scope, and on whether a transfer-pricing study already exists to align the declared value against or one has to be built first. The fee is agreed in writing before work begins.

Transfer pricing — local file — fixed-fee price
From $2,500

in US dollars, fixed and quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
See the full fee page
GST/HST non-resident registration — fixed-fee price
From $400

in US dollars, fixed and quoted before work starts

The registration on the route that fits the business, plus the place-of-supply mapping that decides the rate on each sale and the input recovery position.
See the full fee page
Transfer pricing documentation
From $2,500

in US dollars, fixed and quoted before work starts

Intercompany pricing documented before it is questioned — the functional analysis, the benchmarking and the files that support it.
See the fee schedule
Corporate cross-border filing
From $999

in US dollars, fixed and quoted before work starts

The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.
See the fee schedule
Payroll & mobility setup
From $999

in US dollars, fixed and quoted before work starts

The employer side of mobility — where to register, what to withhold, and what to report once someone works across a border.
See the fee schedule
Individual tax filing
From $349

in US dollars, fixed and quoted before work starts

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
See the fee schedule
Foreign asset & information reporting
From $349

in US dollars, fixed and quoted before work starts

The information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
See the fee schedule
Non-resident & departure filings
From $349

in US dollars, fixed and quoted before work starts

The filings that follow a move: the departure year, the arrival year, and the income that keeps arriving from the country behind you.
See the fee schedule

All published fees on one page — all of it on a single page, so the number you compare is the number you pay.

What the rule does, step by step

Customs and income tax test the same intercompany price with opposite incentives, and satisfying one does not evidence the other.

Customs valuation methods and transfer-pricing methods overlap but are not identical, and related-party transactions attract scrutiny under both. A documented position that reconciles the two is what survives either review.

That mechanism has a practical edge to it: it rewards preparation and punishes discovery. A filer who maps the obligation before the year ends is choosing between options; a filer who finds it afterwards is usually choosing between remedies.

Because a wrong number is worse than no number, every rate and threshold in your file is confirmed for your year at source. Where that confirmation is not available in time, the advice states how the rule works and what would need checking, rather than filling the gap with an estimate. See also retiring abroad from Canada and Canadian subsidiary — cross-border compliance red flags.

What we actually file

  • Reconciliation of platform-collected amounts to your own returns
  • Customs value and transfer-price positions, coordinated
  • Registrations in each jurisdiction where a test is crossed
  • Periodic indirect-tax returns and reconciliations
  • Import, marketplace and reverse-charge documentation

Worked through with figures

The arithmetic is more persuasive than the description, so:

Where a registration obligation actually starts

An online seller with C$351,000 of sales across 7 markets. Assume the largest market takes C$161,460 of that and assume a registration test of C$86,000 in that market.

ItemAmount
Total salesC$351,000
Markets sold into7
Sales in the largest marketC$161,460
Assumed registration test thereC$86,000
Registration required in that market?Yes

One market crosses its own test, so registration and collection start there on the trigger date — and the other 6 markets are tested separately, on their own rules. Registering in one does nothing for the next. The interesting question is where your own figures fall relative to that, which is a computation rather than an opinion.

An illustration, not a client file. The sums are chosen for legibility and the thresholds are stated for the example alone — nothing reaches a filing until it has been confirmed at source for your own year.

What working with us looks like

  1. 1A call to our 24-hour helpline to establish the facts and the dates that matter
  2. 2A written scope and a fixed fee before any work starts
  3. 3Preparation, then a named reviewer's sign-off before anything is filed
  4. 4Filing, then payment — after you have seen and approved the result

Fees for this work

Pricing works the way it should: a defined scope and a fixed fee agreed in writing before anything starts. If the scope turns out to be larger than we thought, that is a conversation before the work, not a line on the bill. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A named reviewer signs off every statutory filing.
  • Documents move through an access-controlled portal rather than email.
  • A change of scope is re-quoted before the work, never added to the invoice after it.

Your next step

The first call establishes whether there is work to do. Everything after that is quoted. One call to our 24-hour helpline is usually enough to tell you whether this is a filing or a project, and what each would cost. The call is free, and we will say so if the answer is that you do not need us.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Business tax advisory, in practice

The search that brings most people to this page is business tax advisory. It is answered here for customs valuation vs transfer price: what creates the obligation, which filings discharge it, and the fee agreed before the work starts.

Customs and income tax test the same intercompany price with opposite incentives, and satisfying one does not evidence the other.

From first contact to filed return

  1. Send the documents as they are

    No tidying required — forward what you have and we tell you what is missing.

  2. Get a fixed quote in writing

    Priced from your actual documents before any work begins, not estimated after.

  3. Both countries prepared together

    One team builds the filings against each other so the relief lands exactly once.

  4. Review, then file

    You approve the finished work before we file it.

What you are actually buying with Customs valuation vs transfer price

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Four terms worth pinning down

Effective tax rate
Tax as a proportion of a defined measure of profit. Under the minimum tax rules it is computed per jurisdiction from adjusted accounting figures.
Arm's length principle
The standard that a controlled transaction should be priced as it would have been between independent enterprises in comparable circumstances.
Economic double taxation
The same profit taxed in two hands — typically after a transfer-pricing adjustment in one country with no corresponding adjustment in the other.
Faceless assessment
India's electronic assessment process, conducted without a designated officer meeting the taxpayer and on deadlines running from the notice.
Customs valuation vs transfer price: Our analysis

Customs valuation methods and transfer-pricing methods overlap but are not identical, and related-party transactions attract scrutiny under both.

Complexity changes the work, not the deal: the written fee and scope come first, a named practitioner signs off, and the filing follows your approval of the delivered file.

Fixed fees around Customs valuation vs transfer price

Timing matters as much as scope. Settling the two positions before a shipment is declared is planning work; doing it once a customs review is already open means reconstructing past entries and explaining adjustments made after the fact. Describe where the file stands on +1 (416) 619-0068.

GST/HST non-resident registration
$400in US dollars, fixed before work starts

Covers: The registration on the route that fits the business, plus the place-of-supply mapping that decides the rate on each sale and the input recovery position.

What makes it bigger: Whether input tax recovery matters. A business with Canadian costs needs the route that permits recovery, and that route brings full compliance with it.

See this fee page
Transfer pricing — local file
$2,500in US dollars, fixed before work starts

Covers: The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.

What makes it bigger: The number of transaction types. Goods, services, royalties and financing are four analyses rather than one, and each needs its own method and its own comparables.

See this fee page
TP benchmarking study
$2,500in US dollars, fixed before work starts

Covers: A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.

What makes it bigger: How defensible the comparables have to be. A study intended for a filing and a study intended to survive an audit are different pieces of work.

See this fee page

The difference a dedicated cross-border team makes

The fee is fixed before we start

Quoted from your documents and agreed in writing. The number you accept is the number you pay.

Late and missed years are ordinary work

An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

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.

The team at work in the open-plan office
The firm’s founder at his desk in the Delhi office

How the work runs — quote first, then the work

  • Step 1: Hand over the paperwork in any state – Sorting it is our job. Send what exists and we identify what is missing from it.
  • Step 2: Priced before a single form is opened – The fee comes from the documents, agreed in writing, and stays where it was agreed.
  • Step 3: One position across every return – The same facts, filed consistently on each side, so nothing contradicts anything else.
  • Step 4: Filed after you have read it – The completed work reaches you before it reaches an authority.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

The rest of this practice

Every link below is a full page of its own — the same depth as this one, for its own subject.

Core services for this situation

Form 926 — transfers to a foreign corporation Form 926 transfer foreign corporation — the guide, the FAQ and the fixed fee.
Form RC269 — foreign plan contributions The full guide to rc269 foreign plan contributions, with the fee fixed before any work starts.
Withholding refund & recovery claims Its own page: withholding refund recovery claims — mechanism, deadlines and published fees.
Canadian receiving a foreign gift Everything on Canadian receiving a foreign gift tax, at the same depth as this page.
Employer of record — the tax risk Employer of record tax risk — the guide, the FAQ and the fixed fee.
Canadian company expanding to the US — LLCs and global taxes The full guide to global taxes LLC, with the fee fixed before any work starts.
Artistes and sportspersons — the treaty article Its own page: artistes sportspersons treaty article — mechanism, deadlines and published fees.
Form T1255 — principal residence (deceased) Everything on t1255 principal residence deceased, at the same depth as this page.
Form W-8IMY — intermediaries Form w-8imy intermediaries — the guide, the FAQ and the fixed fee.

Who we help

Tax for day traders Day traders tax — the guide, the FAQ and the fixed fee.
Tax for influencers & content creators The full guide to influencers & content creators tax, with the fee fixed before any work starts.
Manufacturers cross-border tax Its own page: manufacturers cross border tax — mechanism, deadlines and published fees.
Technology & SaaS — relief you're probably missing Everything on technology & saas relief you're probably missing, at the same depth as this page.
Professors & lecturers — what we charge Professors & lecturers what we charge — the guide, the FAQ and the fixed fee.
Team-sport athletes — relief you're probably missing The full guide to team-sport athletes relief you're probably missing, with the fee fixed before any work starts.
Software developers — relief you're probably missing Its own page: software developers relief you're probably missing — mechanism, deadlines and published fees.
Construction & contracting — what you owe in each country Everything on construction & contracting what you owe in each country, at the same depth as this page.
Software developers — what you owe in each country Software developers what you owe in each country — the guide, the FAQ and the fixed fee.

Countries and corridors this work reaches

Japan tax for expats — country guide Japan tax for expats — the guide, the FAQ and the fixed fee.
Germany tax for expats — country guide The full guide to Germany tax for expats, with the fee fixed before any work starts.
Egypt tax for expats — country guide Its own page: Egypt tax for expats — mechanism, deadlines and published fees.
Nigeria tax for expats — country guide Everything on Nigeria tax for expats, at the same depth as this page.
Thailand tax for expats — country guide Thailand tax for expats — the guide, the FAQ and the fixed fee.
Canada–United States tax corridor The full guide to Canada United States tax, with the fee fixed before any work starts.
Bahrain tax for expats — country guide Its own page: Bahrain tax for expats — mechanism, deadlines and published fees.
US–India tax corridor Everything on US India tax, at the same depth as this page.
Zambia tax for expats — country guide Zambia tax for expats — the guide, the FAQ and the fixed fee.

The people on your file

Named practitioners, each with the countries and the part of a cross-border file they carry, across India, the USA, Canada and the UAE. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE, Legal Quotient Consultants
Udit Gupta
Director, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE

CA (India), CA (Malaysia)

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves any of our offices.

Udit Gupta on LinkedIn

Abhinav Gupta, India international tax, cross-border tax and transfer pricing, Legal Quotient Consultants
Abhinav Gupta
Director, India international tax, cross-border tax and transfer pricing

CA (India)

Indian cross-border files: residents with income abroad, non-residents with income in India, and the treaty relief that ties the Indian return to the one filed in the other country.

Abhinav Gupta on LinkedIn

Raghav Gupta, UAE and India international tax, cross-border tax and transfer pricing, Legal Quotient Consultants
Raghav Gupta
Director, UAE and India international tax, cross-border tax and transfer pricing

FCA (India)

Files that run between the UAE and India: residence, the treaty position, and the benchmarking and documentation behind intercompany pricing.

Raghav Gupta on LinkedIn

Meet the whole team

What these engagements turn on

Case study 1

Related-party importer's customs value reconciled against its transfer price

A company importing goods from a related foreign supplier had its customs declared value and its transfer pricing documentation prepared independently, and needed the two reconciled since customs and income tax test the same price for opposite reasons. We reviewed both positions and reconciled the declared value with the supporting transfer-pricing analysis.

Case study 2

Intercompany price adjustment reviewed for its knock-on customs effect

A business that made a year-end transfer-pricing adjustment to its intercompany price needed the customs implications of that adjustment reviewed, since a change on one side does not automatically flow to the other. We reviewed the adjustment and set out its effect on the company's customs position.

Case study 3

Manufacturer's related-party import price documented for both regimes at once

A manufacturer buying components from a related foreign entity needed its import pricing documented in a way that satisfied both the customs authority's valuation rule and the transfer-pricing rule at the same time. We built the supporting documentation to address both regimes from the same underlying pricing analysis.

Case study 4

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 5

A Foreign Subsidiary That Nobody Had Been Reporting

Owning a company abroad triggers an information return separate from the corporate return, with its own penalty. The work is the surplus and income computations behind it, which also determine how a future dividend is taxed on the way home.

Read how this one runs
Case study 6

A US LLC Owned by a Canadian, Taxed Twice by Design

The two countries classify an LLC differently, so the credit relief that ought to apply frequently does not. The engagement looks at whether the structure can be changed, and where it cannot, at how to make the credit work.

Read how this one runs
Case study 7

Selling Into the US Without an Entity, and Filing in Several States

State obligations are set by each state, and a treaty does not reach them. The review measures activity against each state's own thresholds and separates the states where registration is required from the ones where it is not.

Read how this one runs
Case study 8

A Second Opinion on a Return Already Filed

A cross-border return prepared on one side only is usually right in isolation and wrong in combination. The review checks residence, source and relief in that order, and says plainly whether an amendment is worth making.

Read how this one runs

All case studies — every published engagement in one place.

Where we deliver this work

Every link below is a full page of its own — the same depth as this one, for its own subject.

Where the work is delivered
More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
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
Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
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
Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
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
Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
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
Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Cross-Border Corporate Tax
Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
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
NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
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
T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
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
Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
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
Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate
Importers, Exporters & Manufacturers
  • 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

Customs valuation vs transfer price — questions we are asked

Customs valuation vs transfer price — where does doing it myself start to cost money?

Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: customs valuation methods and transfer-pricing methods overlap but are not identical, and related-party transactions attract scrutiny under both.

What if I have already filed and got it wrong?

That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.

How long will it take?

It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.

Why can a transfer price and a customs value differ for the same shipment?

Transfer pricing rules aim to reflect an arm's length price for income tax purposes, while customs valuation has its own separate framework focused on the value of goods at the border, and the two regimes do not automatically produce the same figure even for an identical intercompany shipment. A price that satisfies one authority's methodology can still be challenged by the other.

Does a later transfer pricing adjustment affect customs declarations already filed?

It can. If an intercompany price is adjusted retroactively to align with a transfer pricing study, the customs value declared at the time of import may no longer match, and several customs authorities require that adjustment to be reported and reconciled rather than left as a mismatch between two filings covering the same goods.

Can one study support both a customs position and a transfer pricing position?

A single study can inform both, but customs authorities generally require their own valuation methodology to be satisfied on its own terms rather than accepting a transfer pricing study as automatic proof of the customs value. We build documentation that anticipates review from both sides rather than assuming one supports the other by default.

What is the arm's length principle?

The standard that a transaction between related parties should be priced as it would have been between independent ones dealing at arm's length. It is the test every major transfer pricing regime applies, and it is evidenced by comparison — finding independent transactions or companies genuinely similar in function, risk and assets, then showing your pricing falls within the range they produce. That comparison is what a benchmarking study documents. See benchmarking study.

What is an advance pricing arrangement?

An agreement with a tax authority, in advance, on how a category of intercompany transactions will be priced for a set number of years. Unilateral arrangements bind one country; bilateral or multilateral ones bind both sides of the transaction and are what actually removes the risk of an adjustment in one country without relief in the other. They take real time and full disclosure, so they suit large recurring flows rather than one-off transactions. See our transfer pricing work.

Tax terms explained
Grossing upFTC basketChapter 4 withholdingRepatriationDeemed disposition on deathNR6Comparable uncontrolled priceReverse chargeAngel taxAdvance rulingResident contributorSection 116 clearanceShadow payrollAdjusted cost base Browse the full A–Z glossary

Related pages

More in this section

All indirect, crypto & advisoryGiving up a green cardEntity selection across bordersTax risk register for cross-border groupsExpatriation tax (US s.877A)Foreign affiliate reorganisationsEU VAT for Canadian sellers

Related work

Cash pooling arrangementsKeeping a home in Canada while abroadNon-resident receiving a Canadian pensionMoving to Canada — a newcomer's first return and benefit claimsUS person with a TFSA or RESP — the reportingProfit split method

Questions on this

Customs valuation vs transfer price — what should I check first?
Fixed fee agreed before we start

A fixed fee for customs valuation vs transfer price

Describe what happened and which countries are involved; the fee comes back in writing before anything begins.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • 18,000+ clients served
  • Re-quoted, never silently invoiced
  • A named reviewer signs off every filing

Our practitioners are alumni of leading accounting and tax institutions

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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