Foreign-owned Canadian company — filings: can I handle this myself?
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: those filings are read together, so the corporate return, the related-party information return and the non-resident slips have to tell one story.
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.
Does my Canadian subsidiary file anything beyond the corporate return?
Usually, yes. The corporate return reports the company's own income. Separately, transactions with the foreign parent and other related non-residents attract a related-party information return, payments made to non-residents attract their own slips, and interests in foreign affiliates attract their own reporting. Each of those is triggered by the relationship rather than by profit, so a subsidiary can owe several filings in a year it made nothing. They are read together. Work out the full set at the start of the year rather than discovering the second and third returns after the first has already been filed on a different basis.
We pay our overseas parent a management fee — what does that create?
Three things at once. The fee is a deduction on the Canadian corporate return, so its amount has to be supportable. It is a transaction with a related non-resident, so it belongs on the related-party information return. And it is a payment to a non-resident, so the question of withholding and a slip arises on the same amount. Those three surfaces are compared. Where the deduction claimed, the amount disclosed and the amount reported as paid to the parent do not match, the follow-up starts with how the fee was set in the first place.
Do we still file if the Canadian company was dormant all year?
A dormant company is still a company with a foreign parent. Intercompany balances, accrued interest, expenses paid by the parent on the subsidiary's behalf and management recharges are all transactions, even where no trade took place and no cash moved. Dormancy also does not end the corporate filing obligation. The practical risk is that nobody prepares anything, because there was nothing to report in the commercial sense, and the information returns are simply missed. If the entity genuinely serves no purpose, that is worth deciding deliberately and winding it up, rather than leaving it to accumulate obligations quietly.
Why does every query we get start with the intercompany pricing?
Because it is the number that drives everything else. The price charged between related companies decides how much profit stays in Canada, how large the deduction is, how much is paid to the non-resident and therefore what is withheld. Change the price and all of those move together. So a reviewer testing whether the Canadian result is right tests the pricing first, and asks for the reasoning that supported it. That reasoning is far easier to produce if it was written when the charge was set, rather than assembled afterwards from invoices that were never meant to explain themselves.
Our parent charges us for software and IT — is that reportable?
A recharge is a transaction with a related non-resident whatever it is called. Software, IT support, use of a group platform, seconded staff time and shared back-office costs all sit inside the related-party reporting, and each one raises its own question about the character of the payment — whether it is a service fee, a right to use something, or a reimbursement of cost. Character matters because it drives whether anything is withheld on payment. Group cost allocations are often posted as a single line in the ledger, and separating that line into its components is usually the first task.
Our three returns disagree with each other — how do we fix that?
Start by deciding which set of figures is actually correct, rather than by amending the one that looks easiest to change. The corporate return, the related-party disclosure and the non-resident slips are three views of the same underlying transactions, so a disagreement means either the ledger is wrong or one preparer worked from different information. That happens often where the parent's advisers prepare one filing and a local bookkeeper prepares another. Reconcile the ledger first, settle the treatment of each intercompany charge, then correct whichever filings do not reflect it, and keep the reasoning on file.
Do NRIs pay tax on money sent to India?
Sending your own funds to India is a transfer of capital, not income, so the remittance itself is not taxed. What is taxable is income the money then earns in India — interest, rent, capital gains — under the rules for the account type it sits in. Sending money out of India is the direction that needs certification before the bank will act. See NRE, NRO and FCNR accounts.
What is a double tax treaty and what does it actually do?
It is an agreement between two countries that divides up the right to tax. Article by article it decides which country taxes employment income, dividends, interest, royalties, pensions, property and business profits — and where both may tax, it caps what the source country can withhold and tells the other to give credit. It also breaks residence ties and opens a government-to-government channel for disputes. What it never does is apply itself: a treaty position is claimed. See our treaty work.
