Affordable s.247 contemporaneous documentation (Canada)

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Canada's documentation rule is a penalty rule: complete and accurate records prepared by the filing deadline are what stand between an adjustment and a penalty on top of it. Affordable s.247 contemporaneous documentation 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.

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  • 15+Years of cross-border experience
  • 18,000+Clients served
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  • 4Global offices — India, USA, Canada & UAE
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Secure a fixed quote

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

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

Canada's documentation rule is a penalty rule: complete and accurate records prepared by the filing deadline are what stand between an adjustment and a penalty on top of it. The records must describe the property or services, the terms, the participants, the functions and risks, the method chosen and why, and the comparables relied on.

Who has to deal with this

  • 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
  • A tax authority has asked whether documentation exists

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.

The team reviewing a file together at a desk

Transparent, fixed pricing for s.247 contemporaneous documentation (Canada)

Contemporaneous documentation for Canada is priced on how many intercompany transactions have to be described and how many years are open: one recurring service charge, documented while the facts are fresh, is a different engagement from a group reconstructing terms, functions and comparables for several past years. Quoted in writing before work starts.

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
See the full fee page

TP benchmarking study — fixed-fee price

From $2,500

fixed, quoted before work starts

A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.
See the full fee page

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

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

Corporate cross-border filing

From $999

fixed, quoted before work starts

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

Payroll & mobility setup

From $999

fixed, quoted before work starts

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

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

Individual tax filing

From $349

fixed, quoted before work starts

A personal filing built from your own documents — employment, investment and rental income across borders, with the treaty position set out.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Late and unfiled years, sequenced and filed together, with the relief available for the delay identified before the first return goes in.
See the fee schedule

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

How the rule actually works

Canada's documentation rule is a penalty rule: complete and accurate records prepared by the filing deadline are what stand between an adjustment and a penalty on top of it.

The records must describe the property or services, the terms, the participants, the functions and risks, the method chosen and why, and the comparables relied on. Prepared after a query, they no longer meet the contemporaneous test.

The rule is therefore less about arithmetic than about proof. Two people with identical numbers can end up in very different positions because one of them can evidence the date, the valuation or the residence and the other cannot.

Where the position depends on a threshold, a rate or a day count, we confirm it against the issuing authority for your own tax year before it goes on a return. Where a figure cannot be verified for your year, we set out the mechanism and quote no number — a wrong threshold on a filed return is worse than an explained one. See also gift city & IFSC structures and annual compliance calendar design.

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

A worked example

It is easier to see with numbers attached.

An operating margin against a tested range

A limited-risk entity with C$35,000,000 of revenue reporting a 1% operating margin. Assume a benchmarking study produced an interquartile range of 5% to 8%.

ItemAmount
RevenueC$35,000,000
Operating margin reported1%
Operating profit reportedC$350,000
Assumed tested range5% – 8%
Profit at the bottom of the rangeC$1,750,000
Potential adjustmentC$1,400,000

A margin below the range invites an adjustment of C$1,400,000 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. Your version of this table is the useful one, and it takes a short call and a document pack to produce.

Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.

What working with us looks like

  1. 1A first call to map the obligations across every country involved
  2. 2A single fixed fee covering the whole set, agreed before we begin
  3. 3Preparation in the order that makes the relief usable, with a reviewer's sign-off
  4. 4You approve the finished work, and we file it

The fixed fee

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

  • Documents move through an access-controlled portal rather than email.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.
  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.

Your next step

The quote comes before the work, in writing. If you want to arrive prepared: the prior-year returns, the dates that matter, and any letter or slip that prompted the question. If you would rather just talk it through first, that works too.

Reviewed 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.

Transfer pricing tax — what this page covers

If you came here for transfer pricing tax, this is where it is dealt with. The subject is s.247 contemporaneous documentation, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

Canada's documentation rule is a penalty rule: complete and accurate records prepared by the filing deadline are what stand between an adjustment and a penalty on top of it.

How the engagement runs, phase by phase

  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.

  2. Fixed fee, defined scope, in writing

    Both agreed before work starts, so the engagement cannot grow into a larger bill.

  3. Prepared together, not passed between firms

    You are not the go-between for two sets of advisers working from two sets of assumptions.

  4. Reviewed, approved, filed

    A named practitioner checks it, you approve it, and then it goes.

How s.247 contemporaneous documentation (Canada) is handled here

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Key terms behind this page, defined

Hybrid surplus
A surplus pool arising principally from certain capital gains of a foreign affiliate, with its own rules on distribution.
Backup withholding
US withholding applied where a payee has not provided a valid taxpayer identification number or certification, independent of any treaty position.
Non-willfulness certification
The signed narrative that is the substance of a streamlined submission. A story that contradicts the filings is what turns relief into an examination.
TDS
Tax deducted at source — the Indian withholding mechanism. Credit is given for what appears against the taxpayer's identifier, not for what the certificate says.
s.247 contemporaneous documentation (Canada): Our analysis

The records must describe the property or services, the terms, the participants, the functions and risks, the method chosen and why, and the comparables relied on.

None of what follows shifts the terms. Scope and fee are settled in writing before anything is prepared, the result carries a named reviewer, and nothing is filed unseen.

S.247 contemporaneous documentation (Canada) — what the published fees look like

Timing changes the work as much as the content. Records assembled by the filing deadline are a documentation exercise; the same records prepared after the CRA has asked a question are an audit response, and priced as one. Whether a fresh comparables search is needed, or an existing one can be refreshed, moves it too.

Corporate cross-border filing

$999fixed, before work starts

Covers: Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Intercompany pricing documented before it is questioned — the functional analysis, the benchmarking and the files that support it.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

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

See this fee page

The difference a dedicated cross-border team makes

A named reviewer on every file

Every page on this site and every file we deliver says which practitioner reviewed it — a person, not a team inbox.

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

The order of filing is planned, not improvised

Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.

The team at work in the open-plan office

How the engagement runs, phase by phase

Step 1

Establishing the facts

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

Step 2

Agreeing the fee

A written scope and a fixed fee before any work starts

Step 3

Drafting and review

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

Step 4

Filing and follow-up

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

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

A fixed quote first, in writing

  • Step 1: Upload the file as it stands – A secure link arrives after the first call. Incomplete is fine; that is what the review is for.
  • Step 2: The number is settled up front – Priced from your own documents and confirmed in writing before any preparation begins.
  • Step 3: Both returns on one desk – One engagement covers every country the file touches, reconciled line against line.
  • Step 4: Your approval, then the filing – The return is yours to check first. We file once you say so.

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.

Core services for this situation

Form 16 / 16A — TDS certificates (India) Form 16 / 16a India — the guide, the FAQ and the fixed fee.
Form 10F — treaty information (India) The full guide to form 10f India, with the fee fixed before any work starts.
Form W-9 — US persons Its own page: form w-9 US persons — mechanism, deadlines and published fees.
Personal services business risk Everything on personal services business risk, at the same depth as this page.
GAAR — general anti-avoidance rules Gaar — general anti-avoidance rules — the guide, the FAQ and the fixed fee.
Indian company setting up in the US The full guide to Indian company setting up in the US, with the fee fixed before any work starts.
Foreign affiliate structure review Its own page: foreign affiliate structure review — mechanism, deadlines and published fees.
US sales tax nexus for foreign sellers Everything on US sales tax nexus for foreign sellers, at the same depth as this page.
Certificate of residency — Canada, US, India Certificate of residency Canada US India — the guide, the FAQ and the fixed fee.

Who we bring this work to

Crypto traders — what you owe in each country Crypto traders what you owe in each country — the guide, the FAQ and the fixed fee.
Tax for franchise owners The full guide to franchise owners tax, with the fee fixed before any work starts.
Day traders — your filing calendar Its own page: day traders your filing calendar — mechanism, deadlines and published fees.
Law firms cross-border tax Everything on law firms cross border tax, at the same depth as this page.
Franchise owners — your filing calendar Franchise owners your filing calendar — the guide, the FAQ and the fixed fee.
Freight forwarders cross-border tax The full guide to freight forwarders cross border tax, with the fee fixed before any work starts.
Airline pilots — your filing calendar Its own page: airline pilots your filing calendar — mechanism, deadlines and published fees.
IT contractors — what you owe in each country Everything on it contractors what you owe in each country, at the same depth as this page.
Tax for physicians & surgeons Physicians & surgeons tax — the guide, the FAQ and the fixed fee.

The corridors we work every week

Brazil tax for expats — country guide Brazil tax for expats — the guide, the FAQ and the fixed fee.
Romania tax for expats — country guide The full guide to romania tax for expats, with the fee fixed before any work starts.
Ghana tax for expats — country guide Its own page: Ghana tax for expats — mechanism, deadlines and published fees.
Georgia tax for expats — country guide Everything on georgia tax for expats, at the same depth as this page.
Pakistan tax for expats — country guide Pakistan tax for expats — the guide, the FAQ and the fixed fee.
Trinidad & Tobago tax for expats — country guide The full guide to Trinidad & tobago tax for expats, with the fee fixed before any work starts.
Canada–Netherlands tax corridor Its own page: Canada Netherlands tax — mechanism, deadlines and published fees.
India–UAE tax corridor Everything on India UAE tax, at the same depth as this page.
Canada–Philippines tax corridor Canada Philippines 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

Cross-border tax case studies

Case study 1

Documentation Built to the US Standard

The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.

Read how this one runs
Case study 2

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
Case study 3

A Foreign Property Form Filed Late, With Penalties Running Daily

The foreign asset return carries a penalty that accrues per day rather than per return, so the exposure grows quietly. Relief is discretionary and it is granted on the reasons given, which means the request is the work rather than the form.

Read how this one runs
Case study 4

Wintering in the US Long Enough to Become a US Filer

Days in the United States accumulate across three years, and enough of them make you a US resident for tax regardless of immigration status. The file counts the days properly and files the statement that keeps the position closer connection rather than residence.

Read how this one runs
Case study 5

An Estate Using Its Graduated Rates in Time

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

Read how this one runs
Case study 6

Choosing Between Methods on the Evidence

A comparable uncontrolled price is the strongest method where one genuinely exists, and reaching for it where it does not is weaker than a properly applied alternative. The choice is documented with the reasons for rejecting the others.

Read how this one runs
Case study 7

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 8

Interest and Penalties Put to a Relief Application

Relief is discretionary and is decided on the circumstances that caused the delay, evidenced year by year. The application is built from the same chronology the filings rest on, so the two cannot contradict each other.

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

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

Athletes, Artists & Entertainers

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

Remote Workers & Digital Nomads

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

Investment Funds & Holding Companies

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

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

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

s.247 contemporaneous documentation (Canada) — questions we are asked

s.247 contemporaneous documentation (Canada) — can I handle this myself?

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 records must describe the property or services, the terms, the participants, the functions and risks, the method chosen and why, and the comparables relied on.

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 does a transfer pricing benchmarking study do?

It evidences that your related-party pricing sits within the range independent parties achieve. The work is comparison: identify companies or transactions genuinely similar in function, risk and assets, compute their margins, and show where your result falls against that range. Done before the filing deadline it supports the position; produced afterwards under audit it carries far less weight. See benchmarking study.

Can you give a plain transfer pricing example?

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

What is country-by-country reporting?

A report that the largest multinational groups file with their home authority, setting out revenue, profit, tax paid and accrued, capital, employees and tangible assets for every jurisdiction they operate in. It is exchanged between authorities and used for risk assessment, not to compute tax. Its effect on the ground is that inconsistency between the report, the local files and the statutory accounts is itself what draws attention. See our transfer pricing work.

Do you give a written opinion?

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

Can you work alongside my existing accountant?

That is how most of our engagements run. They keep the domestic file, we take the cross-border piece, and the scope boundary is agreed in writing so nothing is done twice or missed.

Tax terms explained

Streamlined filingFixed feeStatute-barred yearFixed place of businessLimitation on benefitsForced heirshipImplicit supportRegulation 105Pipeline planningResident contributorQualified domestic minimum top-up taxWithholding agentSubpart F incomeEvidence pack Browse the full A–Z glossary

Related pages

Nearby pages

All transfer pricingManagement fee studyIntercompany loan pricingDo I need transfer pricing documentation?US s.482 documentationCustoms value vs transfer priceCountry-by-country report

Adjacent services

Paying royalties or licence fees abroad — withholdingLocal resident director services in the USCovered expatriate testingSurplus & FAPI computationsLost or stolen crypto claimsDividend repatriation from India

Questions on this

Do I need s.247 contemporaneous documentation?
15+ years of cross-border experience

A fixed fee for s.247 contemporaneous documentation (Canada)

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
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  • 18,000+ clients served

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.

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