Budget-friendly Local file

The local file is where the group's story meets the local entity's numbers, and it is the document a local auditor tests line by line. Budget-friendly local file 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

Your own file sets the fee. Send it over, and a written quote arrives before anything is prepared.

24-hour helpline: +1 (416) 619-0068
  • 24-hour helpline: +1 (416) 619-0068
  • 18,000+ clients served
  • 15+ years of cross-border experience
The short answer

The local file is where the group's story meets the local entity's numbers, and it is the document a local auditor tests line by line. It sets out the entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results.

Who has to deal with this

  • An intercompany charge appeared or changed without an agreement
  • 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

Most people who need help with local file 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 and the team in the open-plan office

Transparent, fixed pricing for local file

A local file is priced on the number of controlled transactions the entity has and on whether its results sit inside the tested range. Where the margin falls outside it, the file has to explain the difference, and that explanation, not the template around it, is where the work sits.

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

Returns for people whose tax position did not stay in one country, including the years residence itself is in question.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

The filings that follow a move: the departure year, the arrival year, and the income that keeps arriving from the country behind you.
See the fee schedule

All published fees on one page — the complete list of what each engagement costs, stated as figures rather than ranges.

How the rule actually works

The local file is where the group's story meets the local entity's numbers, and it is the document a local auditor tests line by line.

It sets out the entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results. Where the entity's actual margin sits outside the tested range, the file has to explain the difference before the auditor does.

Two things follow from that. The first is that the outcome is decided by facts you can arrange and evidence you can keep, rather than by how the return is completed at the end of the year. The second is that sequence matters: the same steps taken in a different order can produce a materially different result, which is why the first conversation is about dates and documents rather than forms.

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 transfer pricing in India — s.92 and form 3ceb and branch or subsidiary — which and why.

What we actually file

  • 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
  • Adjustment and corresponding-adjustment computations

Worked through with figures

The same point, with figures rather than adjectives.

An operating margin against a tested range

A limited-risk entity with C$32,000,000 of revenue reporting a 3% operating margin. Assume a benchmarking study produced an interquartile range of 5% to 10%.

An operating margin against a tested range
ItemAmount
RevenueC$32,000,000
Operating margin reported3%
Operating profit reportedC$960,000
Assumed tested range5% – 10%
Profit at the bottom of the rangeC$1,600,000
Potential adjustmentC$640,000

A margin below the range invites an adjustment of C$640,000 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.

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.

The four steps

  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

Fees for this work

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 local file is smaller than you feared. 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 an access-controlled portal rather than email.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.

How to get this moving

Whatever you have is enough to start the conversation, including nothing but the dates. 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.

Read and approved 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.

Transfer pricing tax — what this page covers

Readers arrive here searching for transfer pricing tax, and local file is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.

The local file is where the group's story meets the local entity's numbers, and it is the document a local auditor tests line by line.

From first contact to filed return

  1. Hand over the paperwork in any state

    Sorting it is our job. Send what exists and we identify what is missing from it.

  2. Priced before a single form is opened

    The fee comes from the documents, agreed in writing, and stays where it was agreed.

  3. One position across every return

    The same facts, filed consistently on each side, so nothing contradicts anything else.

  4. Filed after you have read it

    The completed work reaches you before it reaches an authority.

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

Key terms behind this page, defined

Corresponding adjustment
The matching adjustment in the other country that stops a transfer-pricing assessment taxing the same profit twice. Usually obtained through the treaty procedure.
Form 8865
The US information return for an interest in a foreign partnership, including contributions and dispositions.
Clearance certificate
Confirmation that all amounts owing by a deceased person and their estate have been paid. Distributing without one exposes the representative personally.
Tax protection
A policy under which the employee is reimbursed only if the assignment leaves them worse off, keeping any windfall.
local file: How we read this one

It sets out the entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results.

Complexity changes the work, not the deal: the written fee and scope come first, a named practitioner signs off, and the filing follows your approval of the delivered file.

Fixed fees around local file

Whether a usable functional analysis and comparable set already exist decides the rest: refreshing a local file from a recent study is lighter than building the method, the search and the financial analysis for an entity that has never documented anything. Quoted in writing first.

Corporate cross-border filing

$999fixed, before work starts

Covers: Company filings where income, ownership or operations cross a border, with the related-party disclosures that come with them.

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

What working with us on local file looks like

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

Late and missed years are ordinary work

An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.

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.

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 team at work in the open-plan office

How the engagement runs, phase by phase

Step 1

Initial call

We establish what happened and when, because every position here is anchored to a date

Step 2

Scope and fee

A written scope and a fixed price, so you know the cost before committing

Step 3

Preparation and review

The filings are prepared, cross-checked against each other, and reviewed by name

Step 4

Filing and payment

You see the result, approve it, and we file it

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

The engagement, start to finish

  • Step 1: Tell us the dates and we will tell you the position – Arrival, departure, the years in between — the residence question turns on those before anything else.
  • Step 2: Fixed fee, defined scope, in writing – Both agreed before work starts, so the engagement cannot grow into a larger bill.
  • Step 3: Prepared together, not passed between firms – You are not the go-between for two sets of advisers working from two sets of assumptions.
  • Step 4: Reviewed, approved, filed – A named practitioner checks it, you approve it, and then it goes.

Quoted up front, in writing.

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

More of the same work, from other angles

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

The work we do for clients like this

Foreign-owned US company — filings Everything on foreign-owned US company filings, at the same depth as this page.
IRS streamlined domestic offshore IRS streamlined domestic offshore — the guide, the FAQ and the fixed fee.
NFTs across borders The full guide to NFTs across borders, with the fee fixed before any work starts.
Form A2 — LRS remittance (India) Its own page: form a2 India — mechanism, deadlines and published fees.
Form 26Q — TDS on resident payments (India) Everything on form 26q India, at the same depth as this page.
Form 35 — appeal to CIT(A) (India) Form 35 India — the guide, the FAQ and the fixed fee.
Form NR4 Summary — the return filed with the slips The full guide to NR4 summary return, with the fee fixed before any work starts.
Lower or nil TDS certificate under section 197 Its own page: lower nil TDS certificate section 197 — mechanism, deadlines and published fees.
Capital gains on Indian shares and mutual funds for NRIs Everything on capital gains on Indian shares and mutual funds for NRIs, at the same depth as this page.

Who we bring this work to

Tax for coaches & trainers Everything on coaches & trainers tax, at the same depth as this page.
Dropshipping businesses cross-border tax Dropshipping businesses cross border tax — the guide, the FAQ and the fixed fee.
Physicians & surgeons — relief you're probably missing The full guide to physicians & surgeons relief you're probably missing, with the fee fixed before any work starts.
Tax for restaurant & hospitality owners Its own page: restaurant & hospitality owners tax — mechanism, deadlines and published fees.
Touring musicians — relief you're probably missing Everything on touring musicians relief you're probably missing, at the same depth as this page.
Tax for postdocs & researchers Postdocs & researchers tax — the guide, the FAQ and the fixed fee.
Oil & gas rotational workers — relief you're probably missing The full guide to oil & gas rotational workers relief you're probably missing, with the fee fixed before any work starts.
Tax for lawyers & in-house counsel Its own page: lawyers & in-house counsel tax — mechanism, deadlines and published fees.
Technology & SaaS — what you owe in each country Everything on technology & saas what you owe in each country, at the same depth as this page.

Countries and corridors this work reaches

Romania tax for expats — country guide Everything on romania tax for expats, at the same depth as this page.
Malta tax for expats — country guide Malta tax for expats — the guide, the FAQ and the fixed fee.
Uzbekistan tax for expats — country guide The full guide to uzbekistan tax for expats, with the fee fixed before any work starts.
Thailand tax for expats — country guide Its own page: Thailand tax for expats — mechanism, deadlines and published fees.
Netherlands tax for expats — country guide Everything on Netherlands tax for expats, at the same depth as this page.
Kazakhstan tax for expats — country guide Kazakhstan tax for expats — the guide, the FAQ and the fixed fee.
Canada–United Kingdom tax corridor The full guide to Canada United Kingdom tax, with the fee fixed before any work starts.
Pakistan tax for expats — country guide Its own page: Pakistan tax for expats — mechanism, deadlines and published fees.
Costa Rica tax for expats — country guide Everything on Costa Rica tax for expats, at the same depth as this page.

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

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 2

Whether Documentation Was Required At All

The obligation turns on the transactions that actually happened rather than on the size of the group, and the penalty for contemporaneous documentation is charged by reference to the adjustment. The review establishes which side of the line the company sits.

Read how this one runs
Case study 3

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 4

Documentation Requested, and the Deadline Is Not Extendable

Contemporaneous documentation has to exist by the filing deadline, not be assembled when it is asked for, and the penalty protection turns on that timing. The engagement produces the analysis for the year in question and puts a repeatable process behind the next one.

Read how this one runs
Case study 5

A Canadian Working in the US on a Work Visa

Immigration status and tax residence are different tests, and a visa says nothing about which country taxes the salary. The file fixes residence, applies the employment article, and sequences the two returns so the credit lands where it is usable.

Read how this one runs
Case study 6

An Estate That Cannot Distribute Until the Clearance Comes

An executor who distributes before the clearance certificate can be held personally liable for what is later assessed. The file prepares the final return and the estate return, and applies for the clearance in the order that lets the estate close.

Read how this one runs
Case study 7

A Company Abroad Owned by a US Person

A business incorporated where the owner lives is a foreign corporation to the IRS, with a reporting package of its own and schedules that need local accounts restated. Classification comes first, because it decides what is reportable and when profits are taxed.

Read how this one runs
Case study 8

A Non-Resident Estate Holding US Assets

US situs assets sit inside the US estate tax net regardless of where the owner lived, and the exemption available to a non-resident is not the resident one. The file establishes situs asset by asset before any relief is claimed.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

  • 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

Working from anywhere doesn't mean taxed nowhere: residency defaults, employer payroll exposure and treaty relief decide where income actually lands.

Working from another country does not by itself end tax residence in the one you left, and it can start one where you are sitting. Day counts, ties, the employer's own exposure and the treaty tie-breaker all point at the same question, and the year you move is the year it has to be answered on paper.

  • 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

Local file — questions we are asked

Local file — 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: it sets out the entity's controlled transactions, the functional analysis, the method selected, the comparables and the financial results.

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 the CUP method?

Comparable uncontrolled price. You find the price charged in a comparable transaction between unrelated parties and test your intercompany price against it. It is the most direct of the methods and the most persuasive when it fits, because it compares like with like at the transaction level. Its limit is data: close comparables exist for commodities and standard products, rarely for bespoke services or unique intangibles, which is where the margin-based methods take over. 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.

What if my situation changes mid-year?

Tell us when it happens rather than at filing. Most of what we can do about a change is available in the weeks around it and not afterwards.

What is the most common thing you find on a review?

An unclaimed foreign tax credit, a missed information return, and a treaty position taken without the disclosure the rules required. Usually all three.

24-hour helpline: +1 (416) 619-0068

Ready to deal with local file?

Tell us the situation and we quote in writing before any work starts. You approve the result before it is filed.

  • Re-quoted, never silently invoiced
  • 18,000+ clients served
  • Rated 5.0 out of 5 stars on Google

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