Reasonably priced Intercompany loan pricing

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Pricing an intercompany loan starts with the borrower's own credit standing, not the group's — and the difference between the two is where the analysis lives. Reasonably priced intercompany loan pricing 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

Start by sending whatever paperwork exists — a written fixed quote comes back before any work begins.

24-hour helpline: +1 (416) 619-0068
  • 24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • Fixed fee agreed before work starts
The short answer

Pricing an intercompany loan starts with the borrower's own credit standing, not the group's — and the difference between the two is where the analysis lives. The study establishes a standalone credit rating for the borrower, allowing for implicit group support, then prices term, currency, security and covenants against market data.

Who this applies to

  • 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

Most people who need help with intercompany loan pricing tick at least two of those. If you tick none, we would rather tell you that on a call than take an engagement you do not need.

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

Transparent, fixed pricing for intercompany loan pricing

What drives the fee on intercompany loan pricing is the number of loans to be priced and how much work the borrower’s standalone credit standing takes to establish. A single term loan between two companies sits well below a group with several facilities, currencies and security arrangements to test.

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

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

The employer side of mobility — where to register, what to withhold, and what to report once someone works across a border.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The reporting obligations that attach to owning something abroad, worked out from your holdings rather than from the tax return alone.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

A personal filing built from your own documents — employment, investment and rental income across borders, with the treaty position set out.
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 — all of it on a single page, so the number you compare is the number you pay.

The mechanism, in plain terms

Pricing an intercompany loan starts with the borrower's own credit standing, not the group's — and the difference between the two is where the analysis lives.

The study establishes a standalone credit rating for the borrower, allowing for implicit group support, then prices term, currency, security and covenants against market data. Separately, capital-structure rules can cap the deduction regardless of rate.

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.

Because a wrong number is worse than no number, every rate and threshold in your file is confirmed for your year at source. Where that confirmation is not available in time, the advice states how the rule works and what would need checking, rather than filling the gap with an estimate. See also employer of record — the tax risk and economic substance in the gulf.

What we actually file

  • Advance pricing applications where certainty is worth buying
  • 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 numbers, end to end

The arithmetic is more persuasive than the description, so:

An operating margin against a tested range

A limited-risk entity with C$36,000,000 of revenue reporting a 3% operating margin. Assume a benchmarking study produced an interquartile range of 3% to 8%.

ItemAmount
RevenueC$36,000,000
Operating margin reported3%
Operating profit reportedC$1,080,000
Assumed tested range3% – 8%
Profit at the bottom of the rangeC$1,080,000
Potential adjustmentC$0

The reported margin sits inside the tested range, which is the outcome documentation is meant to demonstrate. Keep the study current: a range computed three years ago is not evidence about this year. Your version of this table is the useful one, and it takes a short call and a document pack to produce.

Example figures throughout, selected to make the rule visible, with rates and thresholds assumed for the demonstration. Your actual filing uses figures confirmed with the issuing authority for your tax year.

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

What you pay, and when

What it costs is settled at the start. We establish the scope on a short call, quote a fixed fee against it in writing, and that is the number on the invoice. Comparable engagements and their fixed fees are set out on the pricing pages.

  • We will tell you when you do not need us, and that call is free.
  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.

Where to go from here

Whatever you have is enough to start the conversation, including nothing but the dates. If you want to arrive prepared: the prior-year returns, the dates that matter, and any letter or slip that prompted the question. If you would rather just talk it through first, that works too.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.

Where transfer pricing tax comes into this file

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

Pricing an intercompany loan starts with the borrower's own credit standing, not the group's — and the difference between the two is where the analysis lives.

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.

What you are actually buying with intercompany loan pricing

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

Certificate of residency
A document from a tax authority confirming residence for a period, required by a foreign payer or authority before it will apply a treaty rate.
Updated return
India's route to voluntarily correct or file late within a statutory window, on payment of additional tax and with limits on what it may do.
Streamlined filing
The US catch-up route for non-willful filers, requiring a limited number of back returns and account reports plus a signed certification. Availability ends when the IRS makes contact first.
Subsidiary
A separate company in the foreign country, which ring-fences liability and creates withholding, transfer pricing and a second set of accounts.
intercompany loan pricing: How we read this one

The study establishes a standalone credit rating for the borrower, allowing for implicit group support, then prices term, currency, security and covenants against market data.

The engagement terms hold no matter what the analysis finds — fee and scope agreed in writing up front, a named reviewer on the output, your approval before the finished work is filed.

Intercompany loan pricing — what the published fees look like

Capital-structure rules are the second variable, because where the deduction can be capped regardless of rate the study has to address that alongside the pricing. Refreshing an existing loan analysis is lighter work than building one. The quote is written before work starts.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

Covers: What an employer owes when an employee works in another country: the registrations, the withholding and the reporting that follow.

See this fee page

The difference a dedicated cross-border team makes

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.

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.

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.

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

How the engagement runs, phase by phase

Step 1

Initial call

We start with the chronology: dates, countries, and what has already been filed

Step 2

Scope and fee

You get the scope and the fee in writing before we touch anything

Step 3

Preparation and review

The work is prepared and reviewed by a named person, not a queue

Step 4

Filing and payment

Nothing is filed until you have read it

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

The engagement, start to finish

  • 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

Keep reading, sideways

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

Services these clients use most

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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.
Form T1255 — principal residence (deceased) Everything on t1255 principal residence deceased, at the same depth as this page.
Indian GST for foreign suppliers Indian GST for foreign suppliers — the guide, the FAQ and the fixed fee.
Management fee study The full guide to management fee study, with the fee fixed before any work starts.
Withholding refund & recovery claims Its own page: withholding refund recovery claims — 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.
Leaving India — becoming an NRI Leaving India — becoming an NRI — the guide, the FAQ and the fixed fee.
Competent authority / MAP request The full guide to competent authority map request, with the fee fixed before any work starts.

Clients who arrive with this exact page

Non-resident landlords — your filing calendar The full guide to non-resident landlords your filing calendar, with the fee fixed before any work starts.
Technology & SaaS — what we charge Its own page: technology & saas what we charge — mechanism, deadlines and published fees.
Crypto traders — what you owe in each country Everything on crypto traders what you owe in each country, at the same depth as this page.
Touring musicians — your filing calendar Touring musicians your filing calendar — the guide, the FAQ and the fixed fee.
Touring musicians — relief you're probably missing The full guide to touring musicians relief you're probably missing, with the fee fixed before any work starts.
Tax for seasonal agricultural workers Its own page: seasonal agricultural workers tax — mechanism, deadlines and published fees.
Professional services firms cross-border tax Everything on professional services firms cross border tax, at the same depth as this page.
Software developers — relief you're probably missing Software developers relief you're probably missing — the guide, the FAQ and the fixed fee.
Franchise owners — your filing calendar The full guide to franchise owners your filing calendar, with the fee fixed before any work starts.

Where our clients live and work

Sweden tax for expats — country guide The full guide to Sweden tax for expats, with the fee fixed before any work starts.
Bangladesh tax for expats — country guide Its own page: Bangladesh tax for expats — mechanism, deadlines and published fees.
Belgium tax for expats — country guide Everything on Belgium tax for expats, at the same depth as this page.
Canada–Mexico tax corridor Canada Mexico tax — the guide, the FAQ and the fixed fee.
Russia tax for expats — country guide The full guide to Russia tax for expats, with the fee fixed before any work starts.
US–Spain tax corridor Its own page: US Spain tax — mechanism, deadlines and published fees.
Malta tax for expats — country guide Everything on Malta tax for expats, at the same depth as this page.
Indonesia tax for expats — country guide Indonesia tax for expats — the guide, the FAQ and the fixed fee.
Ghana tax for expats — country guide The full guide to Ghana 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

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

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 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

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

An Estate Using Its Graduated Rates in Time

The favourable rate treatment an estate can access is time-limited and conditional, and it is lost by administration rather than by decision. The file identifies the window and the filings that keep it open.

Read how this one runs
Case study 7

A US LLC Owned by a Canadian, Taxed Twice by Design

The two countries classify an LLC differently, so the credit relief that ought to apply frequently does not. The engagement looks at whether the structure can be changed, and where it cannot, at how to make the credit work.

Read how this one runs
Case study 8

Inheriting Property in India While Living Abroad

India does not tax the inheritance itself, but the later sale and the money leaving the country both have positions of their own. The file establishes the cost base to use on that sale and what the remittance will require.

Read how this one runs

All case studies — every published engagement in one place.

How and where the work is delivered

Browse sideways: the pages below answer the neighbouring questions.

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

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

Holding structures live or die on treaty access, beneficial ownership and substance — the MLI's principal-purpose test now sits over every arrangement.

A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Intercompany loan pricing — questions we are asked

Intercompany loan pricing — is this a do-it-yourself job?

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 study establishes a standalone credit rating for the borrower, allowing for implicit group support, then prices term, currency, security and covenants against market data.

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.

Do I need transfer pricing documentation?

If your company transacts with a related party in another country, in substance yes — the question is how much. Documentation is what shifts the burden: prepared before the filing deadline it evidences that your pricing was set on arm's length terms, and its absence is what turns a pricing adjustment into a penalty in several regimes. Volume of related-party dealings drives whether you need a local file, a master file, or a full benchmarking study. See do I need transfer pricing documentation.

What is OECD Pillar Two?

A global minimum effective tax for large multinational groups, delivered through top-up taxes rather than a single global rate. Where a group's effective rate in a jurisdiction falls below the agreed minimum, the shortfall is collected — by the parent jurisdiction under the income inclusion rule, by the source jurisdiction under a domestic top-up, or as a backstop by other jurisdictions. Canada has enacted implementing legislation. The compliance burden is data, long before it is tax. See BEPS and Pillar Two.

Can you give a plain transfer pricing example?

A Canadian company manufactures at a cost of one hundred and its US subsidiary sells to customers for one hundred and eighty. If the parent invoices the subsidiary at one hundred and ten, most of the margin is taxed in the United States; invoice at one hundred and seventy and most of it is taxed in Canada. Nothing about the business changed — only which treasury collects. That is why the arm's length price, the one unrelated parties would have agreed, is the reference point both authorities use. See our transfer pricing work.

What if I am behind on filings?

That is a routine engagement rather than an unusual one. We map the unfiled years and obligations first, then advise which catch-up route is open before anything is filed — the order matters more than the speed.

Do you sign the return as preparer?

Where the filing requires a preparer identification, yes. The named reviewer appears on the advice either way, so you always know who stands behind the position.

Tax terms explained

Place of effective managementPaid-up capitalFixed place of businessBenchmarking studyProfit splitAirdropEmigrantTrailing liabilityW-8BENPart XIII taxSection 116 clearanceQualified domestic minimum top-up tax183-day ruleRepatriation Browse the full A–Z glossary

Related pages

Related in this section

All transfer pricingResale price & cost plus methodsTP adjustments & secondary adjustmentsTP audit defence fileAPA — IndiaIntercompany agreementsCorresponding adjustment via MAP

Also relevant

Group restructuring or migrationWinding up a foreign subsidiaryWhy a Canadian should rarely own an LLCGIFT City & IFSC structuresCovered expatriate testingOutbound investment (ODI) from India

Answered questions

Do I need intercompany loan pricing?
Meet us in person at any of our offices

Talk to us about intercompany loan pricing

Describe what happened and which countries are involved; the fee comes back in writing before anything begins.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Fixed fees agreed before work starts
  • 18,000+ clients served
  • A named reviewer signs off every filing

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