Competitively priced Form T1134 supplement — per affiliate

Form T1134 supplement — who files it, when it is due, what late filing costs, and what we charge to prepare it. Canada (CRA). Competitively priced T1134 supplement 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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  • 18,000+ clients served
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In 60 words

Form T1134 supplement is an information return: The per-affiliate supplement to the foreign affiliate return: one set of schedules for each foreign entity in the group. Filers of the foreign affiliate return with more than one affiliate, and groups where affiliates sit under one another.

Who has to deal with this

Filers of the foreign affiliate return with more than one affiliate, and groups where affiliates sit under one another.

The rule underneath it looks like this. Consolidated group accounts do not satisfy it. Each affiliate is reported on its own, in its own currency, with its own income classification — which is why the work scales with entity count rather than revenue.

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

Transparent, fixed pricing for T1134 supplement per affiliate

The T1134 supplement is priced per affiliate, because that is how the work behaves: each foreign entity gets its own set of schedules, its own currency and its own income classification. A dormant holding company and a tiered group of operating subsidiaries are different engagements, and both are quoted in writing first.

T1134 foreign affiliate reporting — fixed-fee price

From $999

fixed, quoted before work starts

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.
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

Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.
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

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

Transfer pricing documentation

From $2,500

fixed, 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

Non-resident & departure filings

From $349

fixed, quoted before work starts

Non-resident filings and the two part-year returns a move produces, sequenced so neither country taxes the same income twice.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

What an employer owes when an employee works in another country: the registrations, the withholding and the reporting that follow.
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 decides whether Form T1134 supplement applies
What the test looks atWhere the figure comes from
The obligationThe per-affiliate supplement to the foreign affiliate return: one set of schedules for each foreign entity in the group.
Who it bindsFilers of the foreign affiliate return with more than one affiliate, and groups where affiliates sit under one another.
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. The date is confirmed for your year at the start of the engagement, not assumed from last year's.

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. If that exposure has already accumulated, it is a disclosure question rather than a filing question, and the assessment comes first.

A worked example

Put numbers against it and the shape of the answer is obvious.

A deemed disposition on the day residency ends

A portfolio bought for C$334,000 is worth C$591,180 on the departure day. Nothing is sold. Assume half the gain enters income and assume a 35% marginal rate on it.

A deemed disposition on the day residency ends
ItemAmount
Cost of the propertyC$334,000
Value on the departure dayC$591,180
Accrued gain treated as realisedC$257,180
Amount assumed to enter incomeC$128,590
Tax at an assumed 35%C$45,007

C$45,007 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. That is an illustration of the mechanism, not a prediction about your file — the same computation on your figures is the first thing we do.

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.

How we prepare and file it, and what it costs

Pricing is settled first: a written scope and a fixed fee for it, before any work begins. See the keeping a home in Canada while abroad for comparable engagements.

The four steps

  1. 1A call to the 24-hour helpline to find out whether this is a filing or a project
  2. 2A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently
  3. 3Preparation against the evidence, with the positions documented as we go
  4. 4Your approval, then the filing — in that order
  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • A named reviewer signs off every statutory filing.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.

If that describes your position, the next step is a short call — not a form.

Reviewed for accuracy 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.

Corporate tax payment CRA, in practice

People reach this page searching for corporate tax payment CRA. It is covered here as it applies to T1134 supplement — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

Consolidated group accounts do not satisfy it.

The four phases of the work

  1. Documents first, questions second

    We read the file before asking anything, so the questions we do ask are the ones that matter.

  2. A quote you can hold us to

    Fixed in writing against a defined scope. No hourly meter, and no revision after the fact.

  3. The order of filing decided deliberately

    Which return goes first can decide whether relief is available at all. That is planned, not discovered.

  4. Nothing filed without your sign-off

    You see the completed work, ask what you need to, and approve it before submission.

The difference a dedicated cross-border team makes

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

Key terms behind this page, defined

Certificate of coverage
The document evidencing which social security system applies to a cross-border worker. Without it, both systems bill.
Joint partner trust
A trust deferring the deemed disposition until the death of the surviving spouse, with the same cross-border caution as an alter ego trust.
Regulation 105
The Canadian withholding on fees paid to a non-resident for services rendered in Canada, computed on gross fees and reducible in advance by a waiver.
Corresponding adjustment
The matching adjustment in the other country that stops a transfer-pricing assessment taxing the same profit twice. Usually obtained through the treaty procedure.
T1134 supplement per affiliate: The practitioner's note

Consolidated group accounts do not satisfy it.

Whichever way the facts cut, you keep the same footing: a fee agreed in writing beforehand, a named practitioner reviewing the file, and nothing filed until the work is delivered and approved.

The published fees closest to T1134 supplement per affiliate

Where a supplement was never filed for earlier years, or an affiliate keeps its statements to local rules and they have to be re-read into Canadian income categories, the T1134 work grows before a single schedule is typed. Those variables are settled and priced in writing before anything begins.

Corporate cross-border filing

$999fixed, before work starts

Covers: Company filings where income, ownership or operations cross a border, with the related-party disclosures that come with them.

See this fee page

Individual tax filing

$349fixed, before work starts

Covers: One engagement for a personal return that touches more than one country: the income, the assets held abroad and the relief claimed against them.

See this fee page

The difference a dedicated cross-border team makes

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.

Both sides prepared together

Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.

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.

The team reviewing a file together at a desk

T1134 supplement per affiliate — the four phases

Step 1

Establishing the facts

A first call to map the obligations across every country involved

Step 2

Agreeing the fee

A single fixed fee covering the whole set, agreed before we begin

Step 3

Drafting and review

Preparation in the order that makes the relief usable, with a reviewer's sign-off

Step 4

Filing and follow-up

You approve the finished work, and we file it

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

The engagement, start to finish

  • Step 1: Start with a conversation about the facts – Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.
  • Step 2: Scope and price, both written down – You get the scope and the fixed fee together, so there is no question later about what was included.
  • Step 3: Prepared by one team, reviewed by a named practitioner – The same people see both sides of the file, and the reviewer signs their name to it.
  • Step 4: Filed, then followed through – Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

Quoted up front, in writing.

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

Where to go next

Browse sideways: the pages below answer the neighbouring questions.

The work we do for clients like this

Canadian receiving a foreign gift The full guide to Canadian receiving a foreign gift tax, with the fee fixed before any work starts.
Regulation 102 waiver Its own page: regulation 102 waiver — mechanism, deadlines and published fees.
Form T3 non-resident beneficiary — reporting Everything on t3 non-resident beneficiary reporting, at the same depth as this page.
Form T1248 — residency information schedule T1248 residency information schedule — the guide, the FAQ and the fixed fee.
Gifting across borders The full guide to gifting across borders, with the fee fixed before any work starts.
Subsection 45(2) & 45(3) — change-of-use elections Its own page: subsection 45(2) 45(3) change of use election — mechanism, deadlines and published fees.
Foreign affiliate reorganisations Everything on foreign affiliate reorganisations, at the same depth as this page.
Form 26Q — TDS on resident payments (India) Form 26q India — the guide, the FAQ and the fixed fee.
LRS limits & TCS on remittances (India) The full guide to LRS limits & TCS on remittances India, with the fee fixed before any work starts.

Who we bring this work to

Day traders — what we charge The full guide to day traders what we charge, with the fee fixed before any work starts.
Professors & lecturers — what we charge Its own page: professors & lecturers what we charge — mechanism, deadlines and published fees.
Cross-border truck drivers — what we charge Everything on cross-border truck drivers what we charge, at the same depth as this page.
Twitch & live streamers — your filing calendar Twitch & live streamers your filing calendar — the guide, the FAQ and the fixed fee.
Technology & SaaS — what we charge The full guide to technology & saas what we charge, with the fee fixed before any work starts.
Cross-border real estate investors cross-border tax Its own page: cross-border real estate investors cross border tax — mechanism, deadlines and published fees.
Tax for restaurant & hospitality owners Everything on restaurant & hospitality owners tax, at the same depth as this page.
Cross-border truck drivers — your filing calendar Cross-border truck drivers your filing calendar — the guide, the FAQ and the fixed fee.
Influencers & content creators — what you owe in each country The full guide to influencers & content creators what you owe in each country, with the fee fixed before any work starts.

Countries and corridors this work reaches

Luxembourg tax for expats — country guide The full guide to Luxembourg tax for expats, with the fee fixed before any work starts.
Belgium tax for expats — country guide Its own page: Belgium tax for expats — mechanism, deadlines and published fees.
Bahrain tax for expats — country guide Everything on Bahrain tax for expats, at the same depth as this page.
Slovenia tax for expats — country guide Slovenia tax for expats — the guide, the FAQ and the fixed fee.
Italy tax for expats — country guide The full guide to Italy tax for expats, with the fee fixed before any work starts.
Mexico tax for expats — country guide Its own page: Mexico tax for expats — mechanism, deadlines and published fees.
Iceland tax for expats — country guide Everything on Iceland tax for expats, at the same depth as this page.
Portugal tax for expats — country guide Portugal tax for expats — the guide, the FAQ and the fixed fee.
Finland tax for expats — country guide The full guide to Finland 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

Interest and Penalties Put to a Relief Application

Relief is discretionary and is decided on the circumstances that caused the delay, evidenced year by year. The application is built from the same chronology the filings rest on, so the two cannot contradict each other.

Read how this one runs
Case study 3

Paid for Work Done in Canada While Living Elsewhere

Employment carried out in Canada is taxable here even where the employer and the bank account are not. The engagement establishes how many of the days were worked in Canada, applies the treaty employment article, and deals with the withholding the payer has already taken.

Read how this one runs
Case study 4

A Canadian Landlord With Property in the United States

Gross withholding on US rents takes no account of mortgage interest, tax or repairs, so a leveraged property can face tax on turnover. An election onto net basis fixes that, and it has its own timing and its own filing.

Read how this one runs
Case study 5

Deemed Resident or Factual Resident — Not the Same File

The two statuses attract different returns, different credits and different provincial treatment, and the label is decided by facts rather than chosen. Establishing which applies is the work; the filing follows from it without argument.

Read how this one runs
Case study 6

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 7

Paying a Beneficiary Who Lives Abroad

Distributions to a non-resident beneficiary carry withholding and a designation that decides its rate. Getting the designation right before the payment avoids recovering the difference through a return afterwards.

Read how this one runs
Case study 8

A Retirement Plan That Grows Tax-Deferred in Only One Country

Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

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

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

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

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

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

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

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

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

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

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

Importers, Exporters & Manufacturers

Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.

Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.

  • 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 T1134 supplement — questions we are asked

Do I file Form T1134 supplement 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. Filers of the foreign affiliate return with more than one affiliate, and groups where affiliates sit under one another.

What happens if I have missed Form T1134 supplement 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 T1134 supplement the same as the other reports I already file?

No. The per-affiliate supplement to the foreign affiliate return: one set of schedules for each foreign entity in the group. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

Are foreign trusts taxable in Canada?

They can be. Canada's deemed-resident-trust rules can pull a non-resident trust into the Canadian tax system where there is a resident contributor or, in some cases, a resident beneficiary — taxing it as though it were resident here. Separate reporting applies to transfers or loans to a non-resident trust and to distributions and debts from one. The planning point is that contributing to an offshore trust from Canada rarely achieves what the brochure suggests. See non-resident trusts.

Branch or subsidiary — which should we use to expand?

A branch keeps one taxpayer: results consolidate at home, losses are usable sooner, and the exposure is that the branch is a permanent establishment whose profit the host country taxes, sometimes with a branch tax on repatriation. A subsidiary is a separate taxpayer with limited liability and local rates, at the cost of withholding on dividends home and transfer pricing on everything between them. The deciding facts are usually expected losses, liability and exit plans. See branch against subsidiary.

What is a permanent establishment, and how easily do we create one?

A taxable presence in another country under the treaty — typically a fixed place of business such as an office, branch, factory or workshop, or a dependent agent habitually concluding contracts on your behalf. Some treaties add a services test measured in days. Purely preparatory or auxiliary activity is excluded, but that carve-out is narrower than it sounds: one senior employee working from home in the other country, with authority, has been enough. See business profits and permanent establishment.

Fixed fee agreed before we start

Talk to us about Form T1134 supplement

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.

  • 24-hour helpline, +1 (416) 619-0068
  • Your existing accountant keeps the domestic file
  • 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.

Request a Quote +1 (416) 619-0068