Budget-friendly Form T106 — non-arm's-length transactions

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Form T106 — who files it, when it is due, what late filing costs, and what we charge to prepare it. Canada (CRA). Budget-friendly T106 with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

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  • 15+Years of cross-border experience
  • 18,000+Clients served
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  • 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
  • 24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
  • Offices in India, the USA, Canada and the UAE
In 60 words

Form T106 is an information return: The information return of non-arm's-length transactions with non-residents — goods, services, royalties, interest, and loans. Canadian corporations, partnerships, trusts and individuals whose reportable transactions with related non-residents exceed the filing threshold.

Who has to deal with this

Canadian corporations, partnerships, trusts and individuals whose reportable transactions with related non-residents exceed the filing threshold.

The question below is the one that actually determines the outcome. This return is the transfer-pricing risk map the CRA reads first. It asks whether documentation exists, so answering it honestly is often the moment a group discovers its intercompany pricing has never been supported.

The team reviewing a file together at a desk

Fixed fees for t106 non arms length transactions, agreed up front

This information return is priced on the shape of the intercompany file: how many related non-residents the Canadian entity deals with, and how many categories of transaction run between them, from goods and services to royalties, interest and loans. Pulling those totals out of a ledger never coded for it is the work. Quoted in writing first.

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, 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

T106 information return — fixed-fee price

From $999

fixed, quoted before work starts

The related-party transaction return, reconciled to the corporate return and to the non-resident slips so the three tell one consistent story.
See the full fee page

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The reporting obligations that attach to owning something abroad, worked out from your holdings rather than from the tax return alone.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.
See the fee schedule

Corporate cross-border filing

From $999

fixed, 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

fixed, quoted before work starts

Registrations, withholding and the employer obligations that follow staff working across a border, set up once and correctly.
See the fee schedule

Individual tax filing

From $349

fixed, 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

Non-resident & departure filings

From $349

fixed, quoted before work starts

Arrival and departure years priced as one engagement, with the part-year residence position and the assets deemed disposed of on exit.
See the fee schedule

All published fees on one page — every engagement, one list, no ranges hiding surprises.

What the reporting test actually looks at

What the test looks atWhere the figure comes from
The obligationThe information return of non-arm's-length transactions with non-residents — goods, services, royalties, interest, and loans.
Who it bindsCanadian corporations, partnerships, trusts and individuals whose reportable transactions with related non-residents exceed the filing threshold.
Jurisdiction and authorityCanada — CRA
Category of filingInformation return

When it is due

Information returns are generally due with — or on the same timetable as — the return they accompany, so the deadline is the filing deadline of the underlying return unless the rules set a separate date. Where an extension covers the return, confirm whether it also covers this form; several information returns keep their own date. We work back from that date to the documents, so the pack is requested early enough to be assembled rather than reconstructed.

What late or missed filing costs

The penalty on an information return is charged per form and per year, and it does not depend on tax being owed. That is the whole risk profile: a filer with no tax to pay can still accumulate a substantial liability across unfiled years, and the exposure compounds with each additional entity or account that should have been reported. Where years are already missed, the route chosen for the earliest year affects the relief available for the rest — so the sequence is decided before anything is filed.

The arithmetic, worked through

The arithmetic is more persuasive than the description, so:

A deemed disposition on the day residency ends

A portfolio bought for C$200,000 is worth C$394,000 on the departure day. Nothing is sold. Assume half the gain enters income and assume a 48% marginal rate on it.

ItemAmount
Cost of the propertyC$200,000
Value on the departure dayC$394,000
Accrued gain treated as realisedC$194,000
Amount assumed to enter incomeC$97,000
Tax at an assumed 48%C$46,560

C$46,560 becomes payable in a year with no sale and no cash. That is what makes the departure date a planning variable: losses realised before it, an election to defer payment against security, and defensible valuations for anything private all change this number. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

Example figures throughout, selected to make the rule visible, with rates and thresholds assumed for the demonstration. Your actual filing uses figures confirmed with the issuing authority for your tax year.

How we prepare and file it, and what it costs

The fee for Form T106 is fixed against a written scope and agreed before we start. It is not billed by the hour and it does not move after the fact. See the Canadian snowbird — the substantial presence test for comparable engagements.

How the engagement runs

  1. 1Establish whether the reporting test is met, on the correct measure
  2. 2Assemble the holdings, accounts or entities that fall inside it
  3. 3Prepare the return and reconcile it to the tax return it travels with
  4. 4File, and set the calendar entry so next year is not a catch-up
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.
  • Consultations scheduled to your working day rather than ours.
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.

Bring last year's returns and we will tell you what is missing.

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

Canada tax forms — what this page covers

Most readers of this page are looking for Canada tax forms. What follows sets out how it works for T106: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

This return is the transfer-pricing risk map the CRA reads first.

How the engagement runs, phase by phase

  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 t106 non arms length transactions

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

The vocabulary this page leans on

Form 3520
The US return reporting transactions with foreign trusts and the receipt of large foreign gifts and bequests — an obligation missed precisely because the receipt is not income.
FEMA
India's exchange-control law, which defines residence differently from tax law and governs which accounts may be held and how funds may move.
Distance selling
Cross-border sales to consumers, which trigger registration in the destination country once its own test is crossed.
Tax home
The main place of business or employment, used to test whether someone is genuinely based abroad. It is distinct from residence and from domicile.
t106 non arms length transactions: The practitioner's note

This return is the transfer-pricing risk map the CRA reads first.

None of what follows shifts the terms. Scope and fee are settled in writing before anything is prepared, the result carries a named reviewer, and nothing is filed unseen.

Fixed fees around t106 non arms length transactions

The return asks whether contemporaneous transfer-pricing documentation exists, and the honest answer changes the engagement: confirming and referencing a study already in place is narrow, building support for pricing that has never been documented is not. A return already past its due date is quoted with the exposure that goes with it.

T106 information return

$999fixed, before work starts

Covers: The related-party transaction return, reconciled to the corporate return and to the non-resident slips so the three tell one consistent story.

What makes it bigger: Inconsistency between the three filings. Where the return, the slips and the schedules disagree, resolving the difference is the engagement rather than the filing.

See this fee page

T1134 foreign affiliate reporting

$999fixed, before work starts

Covers: 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 makes it bigger: 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.

See this fee page

Transfer pricing — local file

$2,500fixed, 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

The difference a dedicated cross-border team makes

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

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.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

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.

Two of the firm’s advisers and the team in the open-plan office

From first call to filed return

Step 1

Establishing the facts

A call to the 24-hour helpline to find out whether this is a filing or a project

Step 2

Agreeing the fee

A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently

Step 3

Drafting and review

Preparation against the evidence, with the positions documented as we go

Step 4

Filing and follow-up

Your approval, then the filing — in that order

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

A fixed quote first, in writing

  • 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

Keep reading, sideways

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

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Students and trainees — the treaty article Its own page: students trainees treaty article — mechanism, deadlines and published fees.
Form W-8IMY — intermediaries Everything on form w-8imy intermediaries, at the same depth as this page.
GST/HST registration — for non-residents, indirect tax Indirect tax — the guide, the FAQ and the fixed fee.
Deemed disposition on death The full guide to deemed disposition on death, with the fee fixed before any work starts.

Clients who arrive with this exact page

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The corridors we work every week

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Denmark tax for expats — country guide Its own page: Denmark tax for expats — mechanism, deadlines and published fees.
Mauritius tax for expats — country guide Everything on mauritius tax for expats, at the same depth as this page.
Malaysia tax for expats — country guide Malaysia tax for expats — the guide, the FAQ and the fixed fee.
Austria tax for expats — country guide The full guide to Austria tax for expats, with the fee fixed before any work starts.
Iceland tax for expats — country guide Its own page: Iceland tax for expats — mechanism, deadlines and published fees.
Romania tax for expats — country guide Everything on romania tax for expats, at the same depth as this page.
Sweden tax for expats — country guide Sweden tax for expats — the guide, the FAQ and the fixed fee.
Barbados tax for expats — country guide The full guide to Barbados tax for expats, with the fee fixed before any work starts.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

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

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

What these engagements turn on

Case study 1

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 2

A Residency Determination Review After Leaving the Country

Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.

Read how this one runs
Case study 3

A Distribution From a Trust Set Up Abroad

A distribution can be capital in the trust's country and income here, and the reporting attaches to the beneficiary rather than the trustee. The work is characterising the payment before it is received where possible.

Read how this one runs
Case study 4

Residency Changed Mid-Year and Both Returns Assumed a Full One

A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.

Read how this one runs
Case study 5

An Estate That Cannot Distribute Until the Clearance Comes

An executor who distributes before the clearance certificate can be held personally liable for what is later assessed. The file prepares the final return and the estate return, and applies for the clearance in the order that lets the estate close.

Read how this one runs
Case study 6

Canadian Dividends and Interest Paid to a Non-Resident

Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.

Read how this one runs
Case study 7

The Deemed Sale That Happens on Death

Canada treats most capital property as sold at fair market value on death, so a terminal return can carry tax on gains nobody realised. Valuations and the order of the returns are what decide the figure.

Read how this one runs
Case study 8

A Home Kept in Canada After the Move Abroad

A dwelling left available is the tie the CRA weighs most heavily, and its treatment differs depending on whether it is rented at arm's length. The file settles the residence position first and the rental reporting second.

Read how this one runs

All case studies — every published engagement in one place.

Delivery, coverage and how we work

Browse sideways: the pages below answer the neighbouring questions.

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

Professional Services Firms

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

  • Reg 105 / 102 waivers
  • Permanent establishment risk
  • Partner mobility planning
  • Cross-border withholding recovery
Explore Professional Services

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

Form T106 — questions we are asked

Do I file Form T106 even if no tax is owed?

Information return obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. Canadian corporations, partnerships, trusts and individuals whose reportable transactions with related non-residents exceed the filing threshold.

What happens if I have missed Form T106 for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form T106 the same as the other reports I already file?

No. The information return of non-arm's-length transactions with non-residents — goods, services, royalties, interest, and loans. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

Which transactions count as non-arms-length for T106 purposes?

The test is the relationship, not the size of the transaction. Dealings with a non-resident you are related to, or with whom you do not deal at arms length in fact, are reportable once the year's total reaches the reporting threshold — and the threshold is measured across all such transactions together, which is how filers who look at each contract separately miss it. Whether a particular counterparty is at arms length is a question of control and of who actually decides the terms, and it is settled from the facts before the summary is prepared.

What is OECD Pillar One?

The part of the international agreement that reallocates a share of taxing rights over the very largest and most profitable groups to the jurisdictions where their customers and users are, regardless of physical presence — plus a simplified approach to routine marketing and distribution returns. It is aimed at the digitalised economy problem that physical-presence rules could not reach, and its implementation is still moving, which is why we read the current instrument rather than the original blueprint. See BEPS and Pillar Two.

Do I need transfer pricing documentation?

If your company transacts with a related party in another country, in substance yes — the question is how much. Documentation is what shifts the burden: prepared before the filing deadline it evidences that your pricing was set on arm's length terms, and its absence is what turns a pricing adjustment into a penalty in several regimes. Volume of related-party dealings drives whether you need a local file, a master file, or a full benchmarking study. See do I need transfer pricing documentation.

Tax terms explained

One-stop schemeSchedule FAForm 926Withholding certificateResident contributorChapter 3 withholdingEffective tax rateCbCRZero-rated supplyForm 8865Departure valuationDependent agentSecure portalPortability Browse the full A–Z glossary

Forms and situations related to Form T106

The rest of this section

All Canadian (CRA) formsGST/HST registration — for non-residents, indirect taxForm NR4 Summary — the return filed with the slipsForm RC267 — US plan contributions (commuters)Form T1135 — foreign income verification statementForm NR302 — partnership declarationForm NR7-R — refund of Part XIII tax

Related work

US grantor trust rules for CanadiansUS estate tax for non-resident aliensTreaty relief for students & researchersForeign seller: capital gains and the clearance certificateCanadian selling US property — capital gains on the sale (FIRPTA)Competent authority / MAP request

Questions on this

Who files Form T106?What is the late filing penalty for Form T106?
15+ years of cross-border experience

Form T106, quoted before we start

One call to the 24-hour helpline is enough to tell you what has to be filed, what it costs, and whether you need us at all.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • A named reviewer signs off every filing
  • Rated 5.0 out of 5 stars on Google
  • Fixed fees agreed before work starts

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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