Documentation, benchmarking, method selection and audit defence.
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24-hour helpline: +1 (416) 619-006830 pages in this section. Documentation, benchmarking, method selection and audit defence.
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Every page in this section is written to the same standard: it opens with the block that exists nowhere else on the site — a threshold, a treaty article, a rule that applies to one group and not the one beside it — and it carries one worked example, worked through in full rather than a set of generalities.
Where a page needs a statutory threshold, a rate or a day-count, that figure is verified against the issuing authority before it ships. Where it cannot be verified for the year in question, the page states the mechanism and quotes no number, because a wrong threshold on a page like this is worse than no page at all. Every statutory page also carries the name of the person who reviewed it and the date they did.
Fees are fixed and agreed in writing before any work begins, and you review the finished work before it is filed. Documents move through a secure portal and you can meet us at any of our offices, so where you are makes no difference to how it works.
Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
30 pages. Documentation, benchmarking, method selection and audit defence. Each one opens with the part that applies to that situation and nowhere else — a threshold, a treaty article, a filing that one group owes and the group beside it does not — and works one example through in full.
The fee is fixed and agreed in writing before any work begins, priced from the documents you send rather than estimated afterwards, and it does not move once accepted. You see the finished work and approve it before anything is filed.
A named adviser reviews every return and every information filing before it goes out, and the statutory pages on this site carry the name of the person who reviewed them and the date they did it. You approve the finished work yourself as the last step.
Send what you have — a return, a notice, a set of statements, in whatever state it is in — through the secure portal after the first call, and you get a written fixed fee back. Or call the 24-hour helpline on +1 (416) 619-0068 and we will tell you what is needed.
The documentation requirement is usually triggered by having cross-border related-party transactions at all, not by the size of the group — a smaller company with one foreign affiliate can still fall within the rules, though the depth of documentation expected scales with the amounts involved.
Documentation describes and supports the pricing decision itself, while benchmarking is the comparable-company analysis used to show the price falls within an arm's-length range — most engagements need both, prepared together rather than one after the other.
The practitioner who prepared and reviewed your file is the one who answers the question about it.
The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.
Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.
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.
Quoted up front, in writing.
Contact Us 24-hour helpline +1 (416) 619-0068We keep the promises short so they stay checkable: a fixed fee in writing before work begins, 18,000+ clients served over 15+ years, and a 5.0/5 Google rating — with the case files published so you can read how engagements actually ended.
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Browse sideways: the pages below answer the neighbouring questions.
A group whose related-party transactions had grown without any formal transfer-pricing documentation needed a first set of documentation prepared before a review made the gap urgent. We reviewed the group's intercompany transactions and prepared the documentation covering the group's actual related-party activity.
A group whose intercompany transaction volume increased significantly needed its transfer-pricing documentation refreshed to reflect the new scale, since the prior documentation no longer matched the group's current activity. We reviewed the change in volume and refreshed the documentation to reflect the group's current position.
A group with several related-party relationships across different countries needed its documentation aligned across all of them at once, so no two files told a different story about the same intercompany terms. We reviewed every relationship together and produced a consistent set of documentation across the whole group.
The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.
Read how this one runsAn interest-free loan between related companies is priced as if it carried interest, and in some cases a deemed benefit follows as well. The file sets a rate against the borrower's own credit profile and documents the terms that support it.
Read how this one runsAn Indian entity with international related-party transactions needs an accountant's report filed by a date of its own, ahead of the return. The work is reconciling the transactions to the books first, because the report is only as defensible as that reconciliation.
Read how this one runsThe master file is a picture of the business rather than of one company, and it has to agree with what each local file says. Assembling it surfaces inconsistencies between entities that nobody had compared.
Read how this one runsContemporaneous documentation has to exist by the filing deadline, not be assembled when it is asked for, and the penalty protection turns on that timing. The engagement produces the analysis for the year in question and puts a repeatable process behind the next one.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
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.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
