Transfer pricing

Documentation, benchmarking, method selection and audit defence.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

Send what you have. We price the engagement from your own documents, in writing, before any work starts.

24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
  • 24-hour helpline: +1 (416) 619-0068
  • Fixed fee agreed before work starts
What is on this page

30 pages in this section. Documentation, benchmarking, method selection and audit defence.

← All cross-border and international tax services

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.

  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Documents move through an access-controlled portal rather than email.

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

Common questions about this section

What does the Transfer pricing section cover?

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.

How are fees set for transfer pricing?

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.

Who checks the work before it 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.

How do I get a quote for transfer pricing?

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.

Fixed fee agreed before we start

Ready to deal with transfer pricing?

Send us the facts. You will get a scope and a fixed fee in writing, and nothing starts until you agree to both.

  • Rated 5.0 out of 5 stars on Google
  • 24-hour helpline, +1 (416) 619-0068
  • Fixed fees agreed before work starts

What working with us on transfer pricing looks like

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

Filed with the authority, not just prepared

The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.

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.

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

How the work runs — quote first, then the work

  • Step 1: Send what you already have – Slips, statements, prior returns — in any order. We list what is still needed after reading them.
  • Step 2: A fee agreed in writing – Quoted from those documents, before the work starts, and it does not move once you accept it.
  • Step 3: Each side drafted against the other – The returns are built together rather than in sequence, so relief is claimed once and in the right country.
  • Step 4: You approve before it is filed – The finished return comes to you first. Nothing is submitted on your behalf unseen.

Quoted up front, in writing.

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

More of the same work, from other angles

Browse sideways: the pages below answer the neighbouring questions.

The work we do for clients like this

RSUs across borders The full guide to rsus across borders, with the fee fixed before any work starts.
Form T1135 — foreign income verification statement Its own page: foreign income verification statement — mechanism, deadlines and published fees.
Form RC269 — foreign plan contributions Everything on rc269 foreign plan contributions, at the same depth as this page.
FLA return — foreign liabilities & assets (India) Fla return India — the guide, the FAQ and the fixed fee.
Indian company setting up in the US The full guide to Indian company setting up in the US, with the fee fixed before any work starts.
Form T5013 — partnership information return Its own page: t5013 partnership information return — mechanism, deadlines and published fees.
Form RC199 — voluntary disclosure application Everything on rc199 voluntary disclosure application, at the same depth as this page.
ODI forms — outbound investment (India) Odi forms India — the guide, the FAQ and the fixed fee.
Substance requirements in practice The full guide to substance requirements in practice, with the fee fixed before any work starts.

Clients who arrive with this exact page

Manufacturers cross-border tax The full guide to manufacturers cross border tax, with the fee fixed before any work starts.
Tax for mining engineers & geologists Its own page: mining engineers & geologists tax — mechanism, deadlines and published fees.
Crypto traders — your filing calendar Everything on crypto traders your filing calendar, at the same depth as this page.
IT contractors — what we charge It contractors what we charge — the guide, the FAQ and the fixed fee.
Twitch & live streamers — relief you're probably missing The full guide to twitch & live streamers relief you're probably missing, with the fee fixed before any work starts.
Tax for railway & transit crew Its own page: railway & transit crew tax — mechanism, deadlines and published fees.
Day traders — what you owe in each country Everything on day traders what you owe in each country, at the same depth as this page.
Influencers & content creators — relief you're probably missing Influencers & content creators relief you're probably missing — the guide, the FAQ and the fixed fee.
Tax for auditors & accountants abroad The full guide to auditors & accountants abroad tax, with the fee fixed before any work starts.

The corridors we work every week

Canada–Philippines tax corridor The full guide to Canada Philippines tax, with the fee fixed before any work starts.
Senegal tax for expats — country guide Its own page: senegal 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.
Canada–United States tax corridor Canada United States tax — the guide, the FAQ and the fixed fee.
Lithuania tax for expats — country guide The full guide to lithuania tax for expats, with the fee fixed before any work starts.
Nepal tax for expats — country guide Its own page: Nepal tax for expats — mechanism, deadlines and published fees.
Canada–Netherlands tax corridor Everything on Canada Netherlands tax, at the same depth as this page.
United States tax for expats — country guide United States tax for expats — the guide, the FAQ and the fixed fee.
US–United Kingdom tax corridor The full guide to US United Kingdom tax, with the fee fixed before any work starts.

Files that look like this one

Case study 1

Documentation Built to the US Standard

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 runs
Case study 2

A Shareholder Loan Across a Border at No Interest

An 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 runs
Case study 3

Indian Transfer Pricing Certification With a Hard Deadline

An 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 runs
Case study 4

A Group File That Had to Describe the Whole Group

The 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 runs
Case study 5

Documentation Requested, and the Deadline Is Not Extendable

Contemporaneous 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 runs
Case study 6

One Employee Working From Another Country

A single remote employee can create payroll registration, withholding and social security obligations in their country, and sometimes a corporate presence too. The review sets out each obligation and the order they have to be registered in.

Read how this one runs
Case study 7

A Pension Taxed Where the Treaty Did Not Intend

Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.

Read how this one runs
Case study 8

A Foreign Affiliate Return Filed Years Late

The reporting obligation on a company held abroad runs separately from the corporate return and carries its own exposure. The work is reconstructing the surplus position across the open years before any filing goes in.

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

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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