Cost-effective Intangibles & DEMPE analysis

Google Rating 5.0Clutch Rating 5.0

Legal ownership of an intangible does not determine who is entitled to its return. Cost-effective intangibles & DEMPE analysis 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.

+1 (416) 619-0068 See fixed fees
  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
Google Rating 5.0Clutch Rating 5.0

Secure a fixed quote

Begin with the papers you already have. The engagement is priced from them, in writing, before the work.

24-hour helpline: +1 (416) 619-0068
  • Fixed fee agreed before work starts
  • 18,000+ clients served
  • 24-hour helpline: +1 (416) 619-0068
The short answer

Legal ownership of an intangible does not determine who is entitled to its return. The analysis identifies which entity performs and controls each of those functions and which bears the associated risk with the financial capacity to do so.

Who this applies to

  • Your customs values and your transfer prices were set by different people
  • An Indian entity is involved, where certification is mandatory regardless of size
  • A year-end adjustment was booked without documenting the basis
  • The benchmarking study on file is more than a couple of years old
  • Your group has any transaction with a related non-resident

If any of that is familiar, keep reading. If none of it is, the shortest route is to describe your own situation and let us name the right page for it.

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

Intangibles & dempe analysis — priced before we start

A DEMPE analysis is priced on how many entities touch the intangible and how many of the functions have to be traced through them — development, enhancement, maintenance, protection and exploitation. One registered owner and one operating company is a contained review; a group where those functions sit in several countries is not.

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

TP benchmarking study — fixed-fee price

From $2,500

fixed, quoted before work starts

A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.
See the full fee page

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

Corporate cross-border filing

From $999

fixed, quoted before work starts

Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Payroll set up for a workforce split across countries, including the relief that stops the same salary being withheld on twice.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

Foreign holdings mapped once — accounts, real property, shareholdings — then reported to each authority in the form it requires.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

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 the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

For a filing history that stopped — the penalty position assessed first, then the years filed in the order that protects it.
See the fee schedule

All published fees on one page — one page, every published fee, nothing quoted as a vague bracket.

What is really being tested

Legal ownership of an intangible does not determine who is entitled to its return. The functions performed — development, enhancement, maintenance, protection and exploitation — do.

The analysis identifies which entity performs and controls each of those functions and which bears the associated risk with the financial capacity to do so. A registered owner with no functions earns a funding return rather than the residual.

The consequence is that intangibles & DEMPE analysis is rarely won or lost on the return itself. It is decided by whether the right document existed at the right moment, and by whether the two countries were dealt with in the order that makes the relief usable rather than merely claimable.

Every statutory figure that reaches your file is checked against the authority that issues it, for the year in question, before anything is filed. Where we cannot verify a number for your year, the advice explains the mechanism instead and says so plainly, because an unverified threshold is a liability rather than a shortcut. See also local resident director services in the US and intercompany loans & thin capitalisation.

What we actually file

  • Local file, master file and country-by-country reporting as applicable
  • The accountant's report where the jurisdiction requires certification
  • Benchmarking studies and functional analyses
  • Intercompany agreements that match the conduct
  • The information return that discloses related-party transactions

The numbers, end to end

Here is the rule doing its work on an actual set of amounts.

An operating margin against a tested range

A limited-risk entity with C$4,000,000 of revenue reporting a 2% operating margin. Assume a benchmarking study produced an interquartile range of 3% to 7%.

ItemAmount
RevenueC$4,000,000
Operating margin reported2%
Operating profit reportedC$80,000
Assumed tested range3% – 7%
Profit at the bottom of the rangeC$120,000
Potential adjustmentC$40,000

A margin below the range invites an adjustment of C$40,000 in this jurisdiction — and unless the other country makes a corresponding adjustment, that profit is taxed twice. The documentation is what turns this into a conversation rather than an assessment. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

These amounts illustrate the mechanism only. The rates and thresholds are assumptions of the example, not your numbers: each is checked against the issuing authority for your specific tax year before any return is filed.

How we handle it

  1. 1A call to our 24-hour helpline to establish the facts and the dates that matter
  2. 2A written scope and a fixed fee before any work starts
  3. 3Preparation, then a named reviewer's sign-off before anything is filed
  4. 4Filing, then payment — after you have seen and approved the result

What you pay, and when

The fee is fixed and agreed in writing before work begins, based on the scope established on the first call. Nothing is billed by the hour, and the number does not move once it is agreed. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • 18,000+ clients served across 4 global offices: India, the USA, Canada and the UAE.
  • A named reviewer signs off every statutory filing.

Where to go from here

Describe the situation in your own words; translating it into forms is our job. The fastest start is a short call and three things: what happened, when it happened, and which countries are involved. Everything else we can ask for as it comes up.

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.

Where transfer pricing tax comes into this file

The subject here is intangibles & DEMPE analysis, which is what people mean when they search for transfer pricing tax. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.

Legal ownership of an intangible does not determine who is entitled to its return.

The four phases of the work

  1. Start with a conversation about the facts

    Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.

  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.

  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.

  4. Filed, then followed through

    Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

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

The vocabulary this page leans on

Excess distribution
A distribution from a foreign pooled investment above a permitted amount, thrown back across the holding period with an interest charge under the default regime.
Stock option benefit
The employment benefit arising on an option, sourced across the period between grant and vest so two countries can tax slices of one gain.
Form 5472
The US information return for reportable transactions between a US corporation, or a foreign-owned US disregarded entity, and its related foreign parties.
Adjusted cost base
The tax cost of property, from which a gain or loss is computed. It resets on arrival in a country and is deemed on emigration.
intangibles & dempe analysis: Our analysis

The analysis identifies which entity performs and controls each of those functions and which bears the associated risk with the financial capacity to do so.

Whatever the file turns out to involve, the terms do not move: the scope and the fee are agreed in writing before any work starts, a named practitioner reviews the result, and nothing is filed until you have approved it.

Intangibles & dempe analysis — what the published fees look like

Cost also turns on whether the intangibles are already identified and their risk allocation documented, or whether the interviews and the contracts have to be reconstructed before anyone can say which entity earns the residual. The fee is agreed in writing before the analysis begins.

Corporate cross-border filing

$999fixed, before work starts

Covers: Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

Covers: Payroll set up for a workforce split across countries, including the relief that stops the same salary being withheld on twice.

See this fee page

The difference a dedicated cross-border team makes

One team, not two firms billing separately

You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.

The order of filing is planned, not improvised

Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.

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

Intangibles & dempe analysis — the four phases

Step 1

Initial call

A short call to work out what actually applies to you and what does not

Step 2

Scope and fee

A written quote against a defined scope, with nothing billed by the hour

Step 3

Preparation and review

We prepare, a named reviewer checks it, and you see it before it goes

Step 4

Filing and payment

You approve, we file, and only then do you pay

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

A fixed quote first, in writing

  • 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

Where to go next

Browse sideways: the pages below answer the neighbouring questions.

Core services for this situation

183-day rules in practice The full guide to 183-day rules in practice, with the fee fixed before any work starts.
Work permit holders Its own page: work permit holders — mechanism, deadlines and published fees.
Hiring a contractor abroad — global payroll tax compliance Everything on global payroll tax compliance, at the same depth as this page.
Form ITR-U — updated return (India) ITR-u India — the guide, the FAQ and the fixed fee.
Choosing a method — CUP The full guide to choosing a method — cup, with the fee fixed before any work starts.
India ↔ Singapore — DTAA Its own page: India ↔ Singapore — DTAA — mechanism, deadlines and published fees.
Non-resident receiving a Canadian pension Everything on non-resident receiving Canadian pension, at the same depth as this page.
Digital services & the marketplace rules Digital services & the marketplace rules — the guide, the FAQ and the fixed fee.
Indian payroll for a foreign employer The full guide to Indian payroll for a foreign employer, with the fee fixed before any work starts.

Clients who arrive with this exact page

Tax for lawyers & in-house counsel The full guide to lawyers & in-house counsel tax, with the fee fixed before any work starts.
IT staffing firms cross-border tax Its own page: it staffing firms cross border tax — mechanism, deadlines and published fees.
Amazon FBA sellers cross-border tax Everything on amazon fba sellers cross border tax, at the same depth as this page.
Touring musicians — what we charge Touring musicians what we charge — the guide, the FAQ and the fixed fee.
Tax for physicians & surgeons The full guide to physicians & surgeons tax, with the fee fixed before any work starts.
Influencers & content creators — what we charge Its own page: influencers & content creators what we charge — mechanism, deadlines and published fees.
Team-sport athletes — relief you're probably missing Everything on team-sport athletes relief you're probably missing, at the same depth as this page.
Nurses working abroad — what you owe in each country Nurses working abroad what you owe in each country — the guide, the FAQ and the fixed fee.
Advisors & referral partners cross-border tax The full guide to advisors & referral partners cross border tax, with the fee fixed before any work starts.

The corridors we work every week

Austria tax for expats — country guide The full guide to Austria tax for expats, with the fee fixed before any work starts.
Morocco tax for expats — country guide Its own page: morocco tax for expats — mechanism, deadlines and published fees.
Tunisia tax for expats — country guide Everything on tunisia tax for expats, at the same depth as this page.
Pakistan tax for expats — country guide Pakistan tax for expats — the guide, the FAQ and the fixed fee.
Spain tax for expats — country guide The full guide to Spain tax for expats, with the fee fixed before any work starts.
Japan tax for expats — country guide Its own page: Japan tax for expats — mechanism, deadlines and published fees.
Israel tax for expats — country guide Everything on Israel tax for expats, at the same depth as this page.
Thailand tax for expats — country guide Thailand tax for expats — the guide, the FAQ and the fixed fee.
Canada–Australia tax corridor The full guide to Canada Australia tax, 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

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 2

The Local File That Has to Match the Accounts

A local file describes the entity's own controlled transactions and ties them to its statutory figures. Where the two do not reconcile, that is what an examiner opens with.

Read how this one runs
Case study 3

Choosing Between Methods on the Evidence

A comparable uncontrolled price is the strongest method where one genuinely exists, and reaching for it where it does not is weaker than a properly applied alternative. The choice is documented with the reasons for rejecting the others.

Read how this one runs
Case study 4

A Country-by-Country Report and Who Files It

The obligation sits with the group and the filing can fall on a surrogate where the parent's jurisdiction does not exchange. Establishing who files where comes before preparing anything.

Read how this one runs
Case study 5

A Margin Defended With a Benchmarking Set That Fits the Facts

A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.

Read how this one runs
Case study 6

Canadian Pension Paid Abroad and Taxed at the Flat Rate

Pension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.

Read how this one runs
Case study 7

A Secondment Whose Paperwork Decided the Tax

Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.

Read how this one runs
Case study 8

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

All case studies — every published engagement in one place.

Where we deliver this work

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

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

Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate

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

Intangibles & DEMPE analysis — questions we are asked

Intangibles & DEMPE analysis — where does doing it myself start to cost money?

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: the analysis identifies which entity performs and controls each of those functions and which bears the associated risk with the financial capacity to do so.

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.

What are the transfer pricing methods?

Five, in two groups. Three compare transactions: comparable uncontrolled price, resale price, and cost plus. Two compare profits: the transactional net margin method, and profit split. The OECD asks for the most appropriate method on the facts rather than a fixed hierarchy; the United States applies a best-method rule to similar effect. Selection is itself a documented judgment, and a method chosen without recording why is a weak position under audit. See our transfer pricing work.

Is "fund transfer pricing" the same thing as transfer pricing?

No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.

What is the difference between a master file and a local file?

The master file describes the group as a whole — its structure, where value is created, how intangibles and financing are held. The local file covers one entity's own related-party transactions in detail, with the analysis supporting each price. Larger groups file both, plus country-by-country reporting above a size threshold, and the thresholds differ by country. See master file vs local file.

Who reviews the work?

A named reviewer signs off every statutory filing, and their name and the review date appear on the advice you receive.

Do you charge for the first meeting?

No. The helpline is open 24 hours a day and the first call is free, and if the conclusion is that there is no work to do we tell you that on the call.

Tax terms explained

Cessation of residenceAdvance taxWithholding taxCompetent authoritySelf-custodyNon-willfulness certificationReassessment noticePublished feeUpdated returnInterquartile rangeUnified creditHypothetical taxTransfer certificateSection 247 penalty Browse the full A–Z glossary

Related pages

The rest of this section

All transfer pricingTP adjustments & secondary adjustmentsProfit split methodChoosing a method — CUPCustoms value vs transfer priceIntercompany loan pricingIntercompany agreements

Connected engagements

GST/HST registration for foreign businessesIndian company setting up in the USIndependent agent and permanent establishment — international taxForeign affiliate reorganisationsHiring an employee in another countryCross-border M&A tax due diligence

Questions on this

Do I need intangibles & DEMPE analysis?
Meet us in person at any of our offices

Intangibles & dempe analysis, quoted before we start

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

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Offices in India, the USA, Canada and the UAE
  • Rated 5.0 out of 5 stars on Google
  • 18,000+ clients served

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