Reasonably priced Intercompany agreements

An intercompany agreement signed after the fact is worse than none at all, because it documents terms the parties demonstrably did not follow. Reasonably priced intercompany agreements 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.

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

Secure a fixed quote

Whatever documents you hold are enough to begin: we read them and put a fixed price in writing first.

24-hour helpline: +1 (416) 619-0068
  • 18,000+ clients served
  • Fixed fee agreed before work starts
  • Google rating 5.0 out of 5
The short answer

An intercompany agreement signed after the fact is worse than none at all, because it documents terms the parties demonstrably did not follow. The agreements should record the services or property, the pricing mechanism, the risk allocation and the term, and they should match the conduct and the invoices.

Who has to deal with this

  • A restructuring moved functions, assets or risks between entities
  • 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

Any two of those together and intercompany agreements is almost certainly your situation. If nothing on the list applies, the helpline call still costs nothing and we will redirect you.

The firm’s founder at his desk in the Delhi office

Transparent, fixed pricing for intercompany agreements

Drafting intercompany agreements is priced by how many agreements are needed and how far the existing conduct and invoices have already drifted from what is written down. Papering a single service arrangement going forward is one job; reconciling several entities’ historic dealings so the agreements match the conduct is another.

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

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

Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.
See the fee schedule

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

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

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

The rule behind the paperwork

An intercompany agreement signed after the fact is worse than none at all, because it documents terms the parties demonstrably did not follow.

The agreements should record the services or property, the pricing mechanism, the risk allocation and the term, and they should match the conduct and the invoices. Where conduct diverges, tax authorities follow the conduct.

What that means in practice is that the work happens before the filing season, not during it. By the time a return is being prepared the facts are fixed; everything that could have changed the answer — a date, an election, a certificate, a valuation — had its own window, and most of those windows close earlier than people expect.

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 covered expatriate testing and SEZ, gift city and tax holidays.

What we actually file

  • 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
  • A defence file of the evidence behind the documentation

What this looks like with numbers

Worked through with figures, the mechanism looks like this.

An operating margin against a tested range

A limited-risk entity with C$37,000,000 of revenue reporting a 1% operating margin. Assume a benchmarking study produced an interquartile range of 4% to 6%.

An operating margin against a tested range
ItemAmount
RevenueC$37,000,000
Operating margin reported1%
Operating profit reportedC$370,000
Assumed tested range4% – 6%
Profit at the bottom of the rangeC$1,480,000
Potential adjustmentC$1,110,000

A margin below the range invites an adjustment of C$1,110,000 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 interesting question is where your own figures fall relative to that, which is a computation rather than an opinion.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

How we handle it

  1. 1We establish what happened and when, because every position here is anchored to a date
  2. 2A written scope and a fixed price, so you know the cost before committing
  3. 3The filings are prepared, cross-checked against each other, and reviewed by name
  4. 4You see the result, approve it, and we file it

What it costs

The commercial part is deliberately boring. One fixed fee for a written scope, agreed up front in writing — which is what lets us tell you honestly when intercompany agreements is smaller than you feared. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.

Your next step

We would rather scope it properly than quote it quickly. One call to our 24-hour helpline is usually enough to tell you whether this is a filing or a project, and what each would cost. The call is free, and we will say so if the answer is that you do not need us.

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.

Transfer pricing meaning, in practice

The search that brings most people to this page is transfer pricing meaning. It is answered here for intercompany agreements: what creates the obligation, which filings discharge it, and the fee agreed before the work starts.

An intercompany agreement signed after the fact is worse than none at all, because it documents terms the parties demonstrably did not follow.

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.

How intercompany agreements is handled here

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

Four terms worth pinning down

Resident contributor
A person resident in the country who transferred or loaned property to a foreign trust — which is enough to make the trust deemed resident under some rules.
Expat
Everyday shorthand for someone living outside their home country. It has no tax meaning at all — residence, citizenship and domicile do the work, and conflating them is where these files start going wrong.
Equalisation levy
An Indian charge on specified digital transactions that sits outside the income tax act, so treaty relief and foreign credit arguments do not work on it in the usual way.
Reverse hybrid
An entity treated as a company by the country of establishment and as transparent by the investor's country, the mirror image of the classic hybrid.
intercompany agreements: How we read this one

The agreements should record the services or property, the pricing mechanism, the risk allocation and the term, and they should match the conduct and the invoices.

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 intercompany agreements

Whether the pricing mechanism and the risk allocation are already settled matters just as much: where they are, the agreement records them; where they are not, they have to be worked out first. Every agreement carries a fixed fee agreed in writing beforehand.

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

Payroll & mobility setup

$999fixed, before work starts

Covers: Registrations, withholding and the employer obligations that follow staff working across a border, set up once and correctly.

See this fee page

Why clients bring intercompany agreements to us

4 global offices

Meet us in person in India, the USA, Canada and the UAE, or send everything through the secure portal — the same process either way.

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.

The quote comes from your documents

Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.

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.

The team reviewing a file together at a desk

From first call to filed return

Step 1

Initial call

A call to our 24-hour helpline to establish the facts and the dates that matter

Step 2

Scope and fee

A written scope and a fixed fee before any work starts

Step 3

Preparation and review

Preparation, then a named reviewer's sign-off before anything is filed

Step 4

Filing and payment

Filing, then payment — after you have seen and approved the result

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

How the work runs — quote first, then the work

  • 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

More of the same work, from other angles

Browse sideways: the pages below answer the neighbouring questions.

Services these clients use most

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Form T1161 — list of properties on emigration Everything on T1161 list of properties emigration, at the same depth as this page.
Staking & yield income Staking & yield income — the guide, the FAQ and the fixed fee.
Keeping a home in Canada while abroad The full guide to keeping a home in Canada while abroad, with the fee fixed before any work starts.
Cash pooling arrangements Its own page: cash pooling arrangements — mechanism, deadlines and published fees.
Non-resident with Canadian dividends or interest Everything on non-resident Canadian dividends interest, at the same depth as this page.
Dividend repatriation from India Dividend repatriation from India — the guide, the FAQ and the fixed fee.
Annual compliance calendar design The full guide to annual compliance calendar design, with the fee fixed before any work starts.
Indian reassessment notices (s.148) Its own page: Indian reassessment notice 148 — mechanism, deadlines and published fees.

Who we help

Twitch & live streamers — what you owe in each country Its own page: twitch & live streamers what you owe in each country — mechanism, deadlines and published fees.
Tax for gig-economy drivers & couriers Everything on gig-economy drivers & couriers tax, at the same depth as this page.
Construction & contracting — what we charge Construction & contracting what we charge — the guide, the FAQ and the fixed fee.
Tax for podcasters The full guide to podcasters tax, with the fee fixed before any work starts.
Tax for it contractors Its own page: it contractors tax — mechanism, deadlines and published fees.
Physicians & surgeons — what you owe in each country Everything on physicians & surgeons what you owe in each country, at the same depth as this page.
Construction & contracting — relief you're probably missing Construction & contracting relief you're probably missing — the guide, the FAQ and the fixed fee.
Tax for data scientists & ai engineers The full guide to data scientists & ai engineers tax, with the fee fixed before any work starts.
Construction & contracting — what you owe in each country Its own page: construction & contracting what you owe in each country — mechanism, deadlines and published fees.

The corridors we work every week

Taiwan tax for expats — country guide Its own page: Taiwan tax for expats — mechanism, deadlines and published fees.
Latvia tax for expats — country guide Everything on latvia tax for expats, at the same depth as this page.
Japan tax for expats — country guide Japan tax for expats — the guide, the FAQ and the fixed fee.
Oman tax for expats — country guide The full guide to Oman tax for expats, with the fee fixed before any work starts.
Ukraine tax for expats — country guide Its own page: Ukraine tax for expats — mechanism, deadlines and published fees.
Bermuda tax for expats — country guide Everything on Bermuda tax for expats, at the same depth as this page.
Colombia tax for expats — country guide Colombia 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.
Hong Kong tax for expats — country guide Its own page: Hong Kong tax for expats — mechanism, deadlines and published fees.

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

Cross-border situations we are engaged for

Case study 1

A Pricing Study That Started With Who Does What

Functions, assets and risks decide which entity should earn the return, and the method follows from that rather than the other way round. Getting the sequence backwards is how a study fails on its first question.

Read how this one runs
Case study 2

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 3

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 4

An Adjustment in One Country and No Relief in the Other

A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.

Read how this one runs
Case study 5

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 6

Branch or Subsidiary, Decided Before Incorporation

The choice changes where profits are taxed, what has to be filed, and whether losses in the early years are usable. It is difficult to reverse once trading has begun, so it is modelled first.

Read how this one runs
Case study 7

A Company That Needed a Resident on Its Board

Several jurisdictions require a locally resident director before a company can be registered or keep its filings current. The requirement is structural and is settled at incorporation rather than discovered at the first annual return.

Read how this one runs
Case study 8

A TFSA That Costs More Than It Saves

Canadian tax-free accounts are not tax-free to a US person, and some of them carry a reporting form of their own. The file is a review of what is held, what each account triggers on the US side, and whether the account is worth keeping once the reporting is priced 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

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

Intercompany agreements — questions we are asked

Intercompany agreements — do I need an adviser, or can I do it alone?

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 agreements should record the services or property, the pricing mechanism, the risk allocation and the term, and they should match the conduct and the invoices.

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 is an advance pricing arrangement?

An agreement with a tax authority, in advance, on how a category of intercompany transactions will be priced for a set number of years. Unilateral arrangements bind one country; bilateral or multilateral ones bind both sides of the transaction and are what actually removes the risk of an adjustment in one country without relief in the other. They take real time and full disclosure, so they suit large recurring flows rather than one-off transactions. See our transfer pricing work.

What is double taxation in a corporation?

That is the economic form: the company pays tax on its profit, then the shareholder pays tax again on the dividend distributed out of that same after-tax profit. Domestic systems soften it with dividend credits or reduced rates on distributions; across borders it is compounded by withholding tax in the paying country. Which relief applies turns on the entity type and the treaty article covering dividends. See repatriating profits.

What is a transfer pricing policy, and is it the same as documentation?

No. The policy is the forward-looking statement of how your intercompany prices are set — which method for which transaction, which comparables, what happens when margins drift. The documentation is the backward-looking evidence that the policy was applied and produced an arm's length result for that year. Authorities read both, and a policy that the intercompany invoices do not actually follow is worse than none, because it establishes what you knew you should have done. See do you need documentation.

Do you give a written opinion?

Where the position warrants one, yes — with the reasoning, the authority relied on, and what would change the answer. It is quoted as part of the scope rather than added afterwards.

Do you work with businesses as well as individuals?

Both, and frequently the same client in both capacities — a founder's personal position and their company's are separate questions that have to be answered together.

No hourly billing, ever

Ready to deal with intercompany agreements?

One short call, one fixed quote in writing, and your approval before anything is filed.

  • 24-hour helpline, +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • Your existing accountant keeps the domestic file

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