Low-cost Master file

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The master file describes the group, not the transaction — and because it is filed in multiple countries, every authority reads the same description of where the group says its value is created. Low-cost master 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.

+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

Send what you have. We price the engagement from your own documents, in writing, before any work starts.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • Google rating 5.0 out of 5
  • 18,000+ clients served
The short answer

The master file describes the group, not the transaction — and because it is filed in multiple countries, every authority reads the same description of where the group says its value is created. It covers structure, business drivers, intangibles, intercompany financing and financial positions.

Do you need this?

  • Margins in one entity look different from the group average
  • 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

That list is deliberately concrete. If you recognise yourself in it, this page is the right starting point; if you do not, tell us and we will point you elsewhere without charging for it.

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

Fixed fees for master file, agreed up front

A master file is priced by the size of the group it has to describe — how many entities, business lines and financing arrangements — and by how many countries will read it. A single operating group is a contained document; a structure holding its intangibles apart from its operations is a longer one.

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

Master file & CbCR — fixed-fee price

From $2,500

fixed, quoted before work starts

The group-level documentation and the country-by-country report, prepared so they agree with each other and with every local file in the footprint.
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

Company filings where income, ownership or operations cross a border, with the related-party disclosures that come with them.
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 information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
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

For anyone taxed by a country they do not live in — rent, pensions and investment income reaching across a border after the move.
See the fee schedule

All published fees on one page — each engagement priced as one number on one list, with nothing left as a range.

What is really being tested

The master file describes the group, not the transaction — and because it is filed in multiple countries, every authority reads the same description of where the group says its value is created.

It covers structure, business drivers, intangibles, intercompany financing and financial positions. Its usefulness is consistency: a local file that contradicts it invites exactly the enquiry the documentation was meant to prevent.

That mechanism has a practical edge to it: it rewards preparation and punishes discovery. A filer who maps the obligation before the year ends is choosing between options; a filer who finds it afterwards is usually choosing between remedies.

The standard here is simple: no figure without a source for your year. Anything that cannot meet it is written as a mechanism, so you can see exactly what the rule does even where the number has to be confirmed before filing. See also why a Canadian should rarely own an LLC and NFTs across borders.

What we actually file

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

The arithmetic, worked through

Worked through with figures, the mechanism looks like this.

An operating margin against a tested range

A limited-risk entity with C$25,000,000 of revenue reporting a 4% operating margin. Assume a benchmarking study produced an interquartile range of 5% to 9%.

ItemAmount
RevenueC$25,000,000
Operating margin reported4%
Operating profit reportedC$1,000,000
Assumed tested range5% – 9%
Profit at the bottom of the rangeC$1,250,000
Potential adjustmentC$250,000

A margin below the range invites an adjustment of C$250,000 in this jurisdiction — and unless the other country makes a corresponding adjustment, that profit is taxed twice. The documentation is what turns this into a conversation rather than an assessment. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

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

The four steps

  1. 1A short call to work out what actually applies to you and what does not
  2. 2A written quote against a defined scope, with nothing billed by the hour
  3. 3We prepare, a named reviewer checks it, and you see it before it goes
  4. 4You approve, we file, and only then do you pay

The fixed fee

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

  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Nothing is filed until you have read it.
  • We will tell you when you do not need us, and that call is free.

Where to go from here

Ask before the move rather than after it, because most of the useful options expire on the date. 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. General guidance only. Your own facts decide the answer, so bring them to a call before relying on this.

Where transfer pricing tax comes into this file

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

The master file describes the group, not the transaction — and because it is filed in multiple countries, every authority reads the same description of where the group says its value is created.

The four phases of the work

  1. Documents first, questions second

    We read the file before asking anything, so the questions we do ask are the ones that matter.

  2. A quote you can hold us to

    Fixed in writing against a defined scope. No hourly meter, and no revision after the fact.

  3. The order of filing decided deliberately

    Which return goes first can decide whether relief is available at all. That is planned, not discovered.

  4. Nothing filed without your sign-off

    You see the completed work, ask what you need to, and approve it before submission.

What you are actually buying with master file

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

Rollback
The extension of an advance pricing agreement to earlier years on the same transactions, available in some countries including India.
Exit charge
A payment for value transferred when functions, assets or risks are moved out of a jurisdiction in a restructuring.
Resident contributor
A person resident in the country who transferred or loaned property to a foreign trust — which is enough to make the trust deemed resident under some rules.
Hybrid mismatch
An outcome — a deduction with no inclusion, or a double deduction — arising from two countries classifying an entity or instrument differently. Anti-hybrid rules now neutralise it.
master file: How we read this one

It covers structure, business drivers, intangibles, intercompany financing and financial positions.

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.

Master file — what the published fees look like

Whether the master file is being refreshed for the year or written for the first time changes the work substantially, as does reconciling it against local files that currently describe the group differently. The fee is agreed in writing before drafting begins.

Transfer pricing — local file

$2,500fixed, before work starts

Covers: 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.

What makes it bigger: The number of transaction types. Goods, services, royalties and financing are four analyses rather than one, and each needs its own method and its own comparables.

See this fee page

Master file & CbCR

$2,500fixed, before work starts

Covers: The group-level documentation and the country-by-country report, prepared so they agree with each other and with every local file in the footprint.

What makes it bigger: The number of jurisdictions. Each one reads the same master file, so an inconsistency anywhere is visible everywhere through information exchange.

See this fee page

TP benchmarking study

$2,500fixed, before work starts

Covers: 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.

What makes it bigger: How defensible the comparables have to be. A study intended for a filing and a study intended to survive an audit are different pieces of work.

See this fee page

Why clients bring master file to us

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.

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.

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.

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.

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

How the engagement runs, phase by phase

Step 1

The opening call

A first call to map the obligations across every country involved

Step 2

Scope in writing

A single fixed fee covering the whole set, agreed before we begin

Step 3

Prepared and checked

Preparation in the order that makes the relief usable, with a reviewer's sign-off

Step 4

Filed, then supported

You approve the finished work, and we file it

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

The engagement, start to finish

  • Step 1: Start with a conversation about the facts – Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.
  • Step 2: Scope and price, both written down – You get the scope and the fixed fee together, so there is no question later about what was included.
  • Step 3: Prepared by one team, reviewed by a named practitioner – The same people see both sides of the file, and the reviewer signs their name to it.
  • Step 4: Filed, then followed through – Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

Quoted up front, in writing.

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

Where to go next

Browse sideways: the pages below answer the neighbouring questions.

Services these clients use most

Pre-immigration tax planning Pre-immigration tax planning — the guide, the FAQ and the fixed fee.
Form T2062B — life insurance disposition The full guide to t2062b life insurance disposition, with the fee fixed before any work starts.
Form T2 Schedule 25 — foreign affiliates Its own page: t2 schedule 25 foreign affiliates — mechanism, deadlines and published fees.
Form T2091 — principal residence exemption: capital gains, foreign Everything on principal residence exemption capital gains foreign property, at the same depth as this page.
Power of attorney for Indian tax matters Power of attorney for Indian tax matters — the guide, the FAQ and the fixed fee.
ODI forms — outbound investment (India) The full guide to odi forms India, with the fee fixed before any work starts.
Form TX19 — estate clearance certificate Its own page: tx19 estate clearance certificate — mechanism, deadlines and published fees.
Canadian working in the US — taxes on a TN, H-1B or L-1 Everything on Canadian working in US taxes, at the same depth as this page.
Form W-8IMY — intermediaries Form w-8imy intermediaries — the guide, the FAQ and the fixed fee.

Clients who arrive with this exact page

Investment funds cross-border tax Investment funds cross border tax — the guide, the FAQ and the fixed fee.
Tax for twitch & live streamers The full guide to twitch & live streamers tax, with the fee fixed before any work starts.
Technology & SaaS — relief you're probably missing Its own page: technology & saas relief you're probably missing — mechanism, deadlines and published fees.
Tax for adult-platform creators Everything on adult-platform creators tax, at the same depth as this page.
Tax for forex traders Forex traders tax — the guide, the FAQ and the fixed fee.
Tax for airline pilots The full guide to airline pilots tax, with the fee fixed before any work starts.
Tax for postdocs & researchers Its own page: postdocs & researchers tax — mechanism, deadlines and published fees.
Tax for physicians & surgeons Everything on physicians & surgeons tax, at the same depth as this page.
Amazon FBA sellers cross-border tax Amazon fba sellers cross border tax — the guide, the FAQ and the fixed fee.

The corridors we work every week

Lithuania tax for expats — country guide Lithuania tax for expats — the guide, the FAQ and the fixed fee.
Canada–Singapore tax corridor The full guide to Canada Singapore tax, with the fee fixed before any work starts.
Netherlands tax for expats — country guide Its own page: Netherlands tax for expats — mechanism, deadlines and published fees.
Iceland tax for expats — country guide Everything on Iceland tax for expats, at the same depth as this page.
Kuwait tax for expats — country guide Kuwait tax for expats — the guide, the FAQ and the fixed fee.
Tanzania tax for expats — country guide The full guide to tanzania tax for expats, with the fee fixed before any work starts.
Uruguay tax for expats — country guide Its own page: uruguay tax for expats — mechanism, deadlines and published fees.
Switzerland tax for expats — country guide Everything on Switzerland tax for expats, at the same depth as this page.
US–United Kingdom tax corridor US United Kingdom tax — the guide, the FAQ and the fixed fee.

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

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

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 4

A Shareholder Loan Across a Border at No Interest

An interest-free loan between related companies is priced as if it carried interest, and in some cases a deemed benefit follows as well. The file sets a rate against the borrower's own credit profile and documents the terms that support it.

Read how this one runs
Case study 5

A US Filer Married to Someone Outside the System

Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.

Read how this one runs
Case study 6

A Penalty Argued on the Facts Rather Than the Form

Reasonable cause is a documented story with dates, not an assertion of good intent. The engagement assembles what the client actually knew and when, and puts the sequence in writing alongside the filings it explains.

Read how this one runs
Case study 7

Gains on Indian Shares Held From Abroad

Holding period and instrument decide the character of the gain, and the deduction at source applies before any of that is considered. The return is where the position is corrected.

Read how this one runs
Case study 8

Treaty Relief Claimed on a Cross-Border Estate

The estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.

Read how this one runs

All case studies — every published engagement in one place.

How and where the work is delivered

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

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

Professional Services Firms

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

  • Reg 105 / 102 waivers
  • Permanent establishment risk
  • Partner mobility planning
  • Cross-border withholding recovery
Explore Professional Services

Importers, Exporters & Manufacturers

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

Athletes, Artists & Entertainers

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

Remote Workers & Digital Nomads

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

Investment Funds & Holding Companies

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

Master file — questions we are asked

Master file — what part of this actually needs a professional?

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 covers structure, business drivers, intangibles, intercompany financing and financial positions.

What if I have already filed and got it wrong?

That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.

How long will it take?

It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.

What are the transfer pricing methods?

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

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.

Do you work with trusts and estates as well as returns?

Yes, and they are frequently the same file: a personal position, an entity position and an estate exposure that all move together.

How do you handle my documents?

Through an access-controlled portal rather than email attachments, with retention limits. Tax records are the most sensitive papers most people own and they are treated that way.

Tax terms explained

Tax equalisationReassessment noticeForeign affiliateSelf-custodyTax protectionDouble taxationRepatriationCompliance calendarStreamlined filingEconomic double taxationSitusDTAAUnified creditNon-resident alien Browse the full A–Z glossary

Related pages

Elsewhere in this section

All transfer pricingGuarantee fee pricingManagement fee studyCustoms value vs transfer priceAdvance pricing arrangement — CanadaUS s.482 documentationAPA — India

Also relevant

GST/HST registration for foreign businessesCustoms valuation vs transfer priceForeign affiliate reorganisationsReal estate holding structuresEmployer of record — the tax riskTrusts before becoming a resident

Answered questions

Do I need master file?
No hourly billing, ever

Let us take master file off your desk

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

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Fixed fees agreed before work starts
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  • 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