Value-priced Management fee study

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A management fee has to survive three questions before its rate is even discussed: was a service actually provided, did the recipient benefit, and would an independent party have paid for it. Ask us about value-priced management fee study: call the 24-hour helpline on +1 (416) 619-0068, or request a written fixed 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

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
  • Fixed fee agreed before work starts
  • Offices in India, the USA, Canada and the UAE
  • 15+ years of cross-border experience
The short answer

A management fee has to survive three questions before its rate is even discussed: was a service actually provided, did the recipient benefit, and would an independent party have paid for it. The study evidences the services with time records and deliverables, excludes shareholder costs, allocates on a defensible key, and tests the mark-up.

Does this bind you?

  • 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
  • Intercompany prices were set internally with no external support

Any two of those together and management fee study 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

Fixed fees for management fee study, agreed up front

A management fee study is priced on how many services are charged and how much evidence exists for them. Where time records and deliverables are already kept, the work is testing the allocation key and the mark-up; where they are not, the services have to be evidenced before any rate can be defended.

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

The transfer pricing file a group needs when goods, services or finance move between its own companies across a border.
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

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

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

Returns for the year you leave, the year you arrive, and the years you earn rental or pension income from a country you no longer live in.
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.

What the rule does, step by step

A management fee has to survive three questions before its rate is even discussed: was a service actually provided, did the recipient benefit, and would an independent party have paid for it.

The study evidences the services with time records and deliverables, excludes shareholder costs, allocates on a defensible key, and tests the mark-up. Failing the benefit test means the deduction is denied while the income remains taxable.

The consequence is that management fee study 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.

Thresholds and rates move, and summaries written for last year are not evidence about this one. So each figure in your file is sourced to the issuing authority for the specific year; anything we cannot source, we describe as a mechanism and leave unquantified until it can be confirmed. See also crypto for corporations and mining income & PE risk.

What we actually file

  • Adjustment and corresponding-adjustment computations
  • 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

The numbers, end to end

The same point, with figures rather than adjectives.

An operating margin against a tested range

A limited-risk entity with C$33,000,000 of revenue reporting a 3% operating margin. Assume a benchmarking study produced an interquartile range of 3% to 8%.

ItemAmount
RevenueC$33,000,000
Operating margin reported3%
Operating profit reportedC$990,000
Assumed tested range3% – 8%
Profit at the bottom of the rangeC$990,000
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. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

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. 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

Fees for this work

Pricing works the way it should: a defined scope and a fixed fee agreed in writing before anything starts. If the scope turns out to be larger than we thought, that is a conversation before the work, not a line on the bill. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A named reviewer signs off every statutory filing.
  • We will tell you when you do not need us, and that call is free.
  • Every statutory figure in your file is verified for your own year at source.

Your next step

Bring last year's returns and we will tell you what is missing. Bring the last two years of returns from each country involved, the slips or certificates for the income in question, and the dates — arrival, departure, or the transaction date. That is enough for us to tell you what has to be filed and what it will cost.

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.

Transfer pricing tax — what this page covers

Most readers of this page are looking for transfer pricing tax. What follows sets out how it works for management fee study: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

A management fee has to survive three questions before its rate is even discussed: was a service actually provided, did the recipient benefit, and would an independent party have paid for it.

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 management fee study

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

Taxpayer relief
The Canadian discretion to cancel or waive penalties and interest — never the tax — for circumstances beyond the taxpayer's control, within a look-back limit.
Compliance calendar
The mapped set of filings by entity and jurisdiction with an owner for each. Deadlines are missed because nobody owns the ones abroad, not because they are unknown.
FBAR
The report of foreign bank and financial accounts filed with the US financial-crimes bureau. It is tested on the aggregate of all foreign accounts at their highest point in the year.
Transfer certificate
The document that releases US-situs assets held by a custodian after a non-resident's death — the practical bottleneck in a cross-border estate.
management fee study: Our analysis

The study evidences the services with time records and deliverables, excludes shareholder costs, allocates on a defensible key, and tests the mark-up.

Whichever way the facts cut, you keep the same footing: a fee agreed in writing beforehand, a named practitioner reviewing the file, and nothing filed until the work is delivered and approved.

Management fee study — what the published fees look like

The number of recipient entities matters too, because the benefit test is applied entity by entity, and shareholder costs have to be stripped out of the pool before it is allocated on a defensible key. The study is quoted in writing before it starts.

Corporate cross-border filing

$999fixed, before work starts

Covers: The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: The transfer pricing file a group needs when goods, services or finance move between its own companies across a border.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

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

See this fee page

Why clients bring management fee study to us

18,000+ clients served

Individuals, expats and corporations across India, the USA, Canada and the UAE have filed with us — 15+ years of cross-border work.

The fee is fixed before we start

Quoted from your documents and agreed in writing. The number you accept is the number you pay.

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.

Filed with the authority, not just prepared

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

The team at work in the open-plan office

Management fee study — the four phases

Step 1

First conversation

A call to the 24-hour helpline to find out whether this is a filing or a project

Step 2

Written quote

A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently

Step 3

Preparation and sign-off

Preparation against the evidence, with the positions documented as we go

Step 4

Submission

Your approval, then the filing — in that order

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

The rest of this practice

Each of these carries its own guide, pricing pointers and FAQ.

The work we do for clients like this

APA — India Everything on apa — India, at the same depth as this page.
PAN and Aadhaar for non-residents PAN and aadhaar for non-residents — the guide, the FAQ and the fixed fee.
Form A2 — LRS remittance (India) The full guide to form a2 India, with the fee fixed before any work starts.
Corporate emigration from Canada Its own page: corporate emigration from Canada — mechanism, deadlines and published fees.
Canadian company opening in India Everything on Canadian company opening in India, at the same depth as this page.
CPP/EI vs FICA for cross-border staff Cpp/ei vs fica for cross-border staff — the guide, the FAQ and the fixed fee.
Crypto trading vs investing The full guide to crypto trading vs investing, with the fee fixed before any work starts.
Advance pricing arrangement — Canada Its own page: advance pricing arrangement — Canada — mechanism, deadlines and published fees.
Cash pooling arrangements Everything on cash pooling arrangements, at the same depth as this page.

Who we help

Team-sport athletes — your filing calendar Everything on team-sport athletes your filing calendar, at the same depth as this page.
Agriculture & agri-tech cross-border tax Agriculture & agri-tech cross border tax — the guide, the FAQ and the fixed fee.
IT staffing firms cross-border tax The full guide to it staffing firms cross border tax, with the fee fixed before any work starts.
Physicians & surgeons — your filing calendar Its own page: physicians & surgeons your filing calendar — mechanism, deadlines and published fees.
Tax for management consultants Everything on management consultants tax, at the same depth as this page.
Influencers & content creators — what we charge Influencers & content creators what we charge — the guide, the FAQ and the fixed fee.
Franchise owners — what we charge The full guide to franchise owners what we charge, with the fee fixed before any work starts.
Importers & exporters cross-border tax Its own page: importers & exporters cross border tax — mechanism, deadlines and published fees.
Seafarers & mariners — what we charge Everything on seafarers & mariners what we charge, at the same depth as this page.

The corridors we work every week

US–Spain tax corridor Everything on US Spain tax, at the same depth as this page.
Uzbekistan tax for expats — country guide Uzbekistan tax for expats — the guide, the FAQ and the fixed fee.
Armenia tax for expats — country guide The full guide to armenia tax for expats, with the fee fixed before any work starts.
Italy tax for expats — country guide Its own page: Italy tax for expats — mechanism, deadlines and published fees.
Cyprus tax for expats — country guide Everything on Cyprus tax for expats, at the same depth as this page.
Saudi Arabia tax for expats — country guide Saudi Arabia tax for expats — the guide, the FAQ and the fixed fee.
Estonia tax for expats — country guide The full guide to Estonia tax for expats, with the fee fixed before any work starts.
Switzerland tax for expats — country guide Its own page: Switzerland tax for expats — mechanism, deadlines and published fees.
Nepal tax for expats — country guide Everything on Nepal 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

Files that look like this one

Case study 1

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 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

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 4

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 5

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 6

A US LLC Owned From Canada

The two countries classify the vehicle differently, so relief that ought to apply frequently does not and the same profit can be taxed in both hands. The engagement examines whether the structure can be changed and what the change itself costs.

Read how this one runs
Case study 7

First Canadian Return After Arriving Mid-Year

The arrival date splits the year and sets the cost base of what you brought with you. Getting that date and those values right is what determines whether a later sale is taxed on the whole gain or only on the part that accrued after landing.

Read how this one runs
Case study 8

Two Wills, Two Jurisdictions, One Estate

A will drawn for one country can revoke another or fail to reach assets held abroad. The review checks how each instrument interacts with the other and where probate will actually be required.

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

Importers, Exporters & Manufacturers

Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.

Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

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

Management fee study — questions we are asked

Management fee study — 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 study evidences the services with time records and deliverables, excludes shareholder costs, allocates on a defensible key, and tests the mark-up.

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 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.

What is OECD Pillar One?

The part of the international agreement that reallocates a share of taxing rights over the very largest and most profitable groups to the jurisdictions where their customers and users are, regardless of physical presence — plus a simplified approach to routine marketing and distribution returns. It is aimed at the digitalised economy problem that physical-presence rules could not reach, and its implementation is still moving, which is why we read the current instrument rather than the original blueprint. See BEPS and Pillar Two.

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.

When do I pay?

After the work is finished and you have approved it. You see the completed return or filing before any payment is made.

Do I have to come to an office?

No, though you are welcome to: we have offices in India, the USA, Canada and the UAE. Documents move through a secure portal and meetings can be in person or by video, arranged around your time zone, which is how clients across Canada, the United States, the Gulf and India work with us.

Tax terms explained

Resale price methodT1135Withholding taxTransfer certificateMaster fileDeparture taxPANSection 247 penaltyForm 15CADelinquent FBARSubstance-based income exclusionNRE accountChapter 3 withholdingPresumptive taxation Browse the full A–Z glossary

Related pages

More in this section

All transfer pricingAdvance pricing arrangement — CanadaCost-sharing arrangementss.247 contemporaneous documentation (Canada)US s.482 documentationGuarantee fee pricingCountry-by-country report

Also relevant

Marketplace facilitator rulesControlled foreign corporation rules — international taxInternational tax planningCrypto trading vs investingAdvance pricing agreements in IndiaUS sales tax nexus for foreign sellers

Common questions here

Do I need management fee study?
A named reviewer on every filing

A fixed fee for management fee study

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

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Re-quoted, never silently invoiced
  • 18,000+ clients served
  • 24-hour helpline, +1 (416) 619-0068

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