Competitively priced TP adjustments & secondary adjustments

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A transfer-pricing adjustment rarely arrives alone. Competitively priced TP adjustments & secondary adjustments 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
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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
  • Fixed fee agreed before work starts
  • Google rating 5.0 out of 5
The short answer

A transfer-pricing adjustment rarely arrives alone. Secondary adjustments can treat the difference as a deemed loan or a deemed dividend, with interest or withholding attached.

Who this applies to

  • Intercompany prices were set internally with no external support
  • A tax authority has asked whether documentation exists
  • 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

One of those is usually enough to make this worth a conversation. If none of them fits, say so on the call and we will find the page that does.

The team reviewing a file together at a desk

Transparent, fixed pricing for tp adjustments & secondary adjustments

What drives the fee on a transfer-pricing adjustment is what follows the primary adjustment: how many years are reopened, how many countries have to be brought into line, and whether a secondary adjustment has to be unwound through a repatriation arrangement rather than left to run as a deemed loan or dividend.

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

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

Non-resident & departure filings

From $349

fixed, quoted before work starts

Arrival and departure years priced as one engagement, with the part-year residence position and the assets deemed disposed of on exit.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

Personal returns for individuals, expats and non-residents — foreign income, foreign property and treaty relief handled in one engagement.
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

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

How the rule actually works

A transfer-pricing adjustment rarely arrives alone. The primary adjustment changes the profit, and a secondary adjustment then characterises the money that never moved.

Secondary adjustments can treat the difference as a deemed loan or a deemed dividend, with interest or withholding attached. Repatriation arrangements and the treaty's corresponding-adjustment article are the tools that limit the compounding.

This is why we start with a chronology rather than a form. Almost every position in this area is anchored to a date — of arrival, of departure, of a payment, of a transaction — and the evidence that supports it is either created around that date or reconstructed years later at several times the cost.

Every statutory figure that reaches your file is checked against the authority that issues it, for the year in question, before anything is filed. Where we cannot verify a number for your year, the advice explains the mechanism instead and says so plainly, because an unverified threshold is a liability rather than a shortcut. See also transfer pricing in India — s.92 and form 3ceb and Canadian subsidiary — cross-border compliance red flags.

What we actually file

  • Advance pricing applications where certainty is worth buying
  • Local file, master file and country-by-country reporting as applicable
  • The accountant's report where the jurisdiction requires certification
  • Benchmarking studies and functional analyses
  • Intercompany agreements that match the conduct

Worked through with figures

It is easier to see with numbers attached.

An operating margin against a tested range

A limited-risk entity with C$18,000,000 of revenue reporting a 2% operating margin. Assume a benchmarking study produced an interquartile range of 5% to 8%.

ItemAmount
RevenueC$18,000,000
Operating margin reported2%
Operating profit reportedC$360,000
Assumed tested range5% – 8%
Profit at the bottom of the rangeC$900,000
Potential adjustmentC$540,000

A margin below the range invites an adjustment of C$540,000 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. That is an illustration of the mechanism, not a prediction about your file — the same computation on your figures is the first thing we do.

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.

How we handle it

  1. 1A call to the 24-hour helpline to find out whether this is a filing or a project
  2. 2A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently
  3. 3Preparation against the evidence, with the positions documented as we go
  4. 4Your approval, then the filing — in that order

What you pay, and when

You get a number before you commit, not an estimate that drifts. The scope is written down, the fee is fixed against it, and if the scope changes we re-quote rather than invoice the difference. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Nothing is filed until you have read it.
  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.

Your next step

Ask before the move rather than after it, because most of the useful options expire on the date. Send whatever you have — even an incomplete set. Most of the first hour of a TP adjustments & secondary adjustments engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

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.

Where transfer pricing tax comes into this file

People reach this page searching for transfer pricing tax. It is covered here as it applies to TP adjustments & secondary adjustments — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

A transfer-pricing adjustment rarely arrives alone.

The four phases of the work

  1. Send what you already have

    Slips, statements, prior returns — in any order. We list what is still needed after reading them.

  2. A fee agreed in writing

    Quoted from those documents, before the work starts, and it does not move once you accept it.

  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.

  4. You approve before it is filed

    The finished return comes to you first. Nothing is submitted on your behalf unseen.

How tp adjustments & secondary adjustments 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

Four terms worth pinning down

Advance ruling
A binding determination of the tax treatment of a proposed transaction, obtained before the transaction is carried out.
Corresponding adjustment
The matching adjustment in the other country that stops a transfer-pricing assessment taxing the same profit twice. Usually obtained through the treaty procedure.
Dual citizenship
Holding two nationalities. It changes nothing for a residence-based system and everything for a citizenship-based one, which is why one passport can create a lifelong filing obligation.
Section 216
The Canadian elective return that taxes a non-resident's net rental profit at graduated rates instead of gross rent at the flat withholding rate.
tp adjustments & secondary adjustments: How we read this one

Secondary adjustments can treat the difference as a deemed loan or a deemed dividend, with interest or withholding attached.

Whatever the file turns out to involve, the terms do not move: the scope and the fee are agreed in writing before any work starts, a named practitioner reviews the result, and nothing is filed until you have approved it.

Fixed fees around tp adjustments & secondary adjustments

Claiming the corresponding adjustment is a separate track: relief under the treaty is put to another country's authority, on its own timetable, and the same facts have to be argued a second time. Whether withholding or interest has already been assessed on the secondary adjustment changes the scope again.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.

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: 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 tp adjustments & secondary adjustments to us

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

Late and missed years are ordinary work

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

The fee is fixed before we start

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

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 firm’s founder at his desk in the Delhi office

How the engagement runs, phase by phase

Step 1

Establishing the facts

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

Step 2

Agreeing the fee

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

Step 3

Drafting and review

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

Step 4

Filing and follow-up

Nothing is filed until you have read it

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

How the work runs — quote first, then the work

  • Step 1: Share your documents – A secure upload link arrives after the first call — send files in any state.
  • Step 2: A written fixed fee – The quote is fixed from what you send; it does not move once accepted.
  • Step 3: Preparation, both sides at once – The returns are drafted together, reconciled line against line.
  • Step 4: Approve, then file – Nothing is filed until you have seen it and approved it.

Quoted up front, in writing.

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

The rest of this practice

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

Core services for this situation

Country-by-country report Everything on country-by-country report, at the same depth as this page.
Form 8288-C — section 1446(f) withholding Form 8288-c section 1446f withholding — the guide, the FAQ and the fixed fee.
Importing into Canada — GST & duty The full guide to importing into Canada — GST & duty, with the fee fixed before any work starts.
Treaty-based structuring reviews Its own page: treaty-based structuring reviews — mechanism, deadlines and published fees.
Form 3520 — foreign gifts & trusts Everything on form 3520 foreign gifts trusts, at the same depth as this page.
Schedule FSI — foreign source income (India) Schedule fsi India — the guide, the FAQ and the fixed fee.
US person married to a non-resident spouse The full guide to US person married non-resident spouse, with the fee fixed before any work starts.
Study permit holders Its own page: study permit holders — mechanism, deadlines and published fees.
Social security totalization agreements — Canada and the US Everything on social security totalization agreement Canada US, at the same depth as this page.

Who we help

Tax for corporate & charter pilots Everything on corporate & charter pilots tax, at the same depth as this page.
Tax for gig-economy drivers & couriers Gig-economy drivers & couriers tax — the guide, the FAQ and the fixed fee.
Crypto traders — what you owe in each country The full guide to crypto traders what you owe in each country, with the fee fixed before any work starts.
Crypto traders — your filing calendar Its own page: crypto traders your filing calendar — mechanism, deadlines and published fees.
Tax for nurses working abroad Everything on nurses working abroad tax, at the same depth as this page.
Software developers — what you owe in each country Software developers what you owe in each country — the guide, the FAQ and the fixed fee.
Architecture practices cross-border tax The full guide to architecture practices cross border tax, with the fee fixed before any work starts.
Tax for international school staff Its own page: international school staff tax — mechanism, deadlines and published fees.
Construction & contracting — what we charge Everything on construction & contracting what we charge, at the same depth as this page.

Countries and corridors this work reaches

US–Mexico tax corridor Everything on US Mexico tax, at the same depth as this page.
Uruguay tax for expats — country guide Uruguay tax for expats — the guide, the FAQ and the fixed fee.
Ghana tax for expats — country guide The full guide to Ghana tax for expats, with the fee fixed before any work starts.
Canada–Netherlands tax corridor Its own page: Canada Netherlands tax — mechanism, deadlines and published fees.
Mexico tax for expats — country guide Everything on Mexico tax for expats, at the same depth as this page.
Kenya tax for expats — country guide Kenya tax for expats — the guide, the FAQ and the fixed fee.
Costa Rica tax for expats — country guide The full guide to Costa Rica tax for expats, with the fee fixed before any work starts.
Senegal tax for expats — country guide Its own page: senegal tax for expats — mechanism, deadlines and published fees.
Estonia tax for expats — country guide Everything on Estonia tax for expats, at the same depth as this page.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

What these engagements turn on

Case study 1

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

Two Passports, Two Returns, One Income

Dual citizenship does not let you choose which country taxes you. The work is establishing residence, applying the treaty article that governs each income type, and preparing both returns from one set of figures so they agree line for line.

Read how this one runs
Case study 3

A Family Trust Abroad With Reporting on Both Sides

A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.

Read how this one runs
Case study 4

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 5

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 6

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 7

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 8

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

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

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

TP adjustments & secondary adjustments — questions we are asked

TP adjustments & secondary adjustments — 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: secondary adjustments can treat the difference as a deemed loan or a deemed dividend, with interest or withholding attached.

What if I have already filed and got it wrong?

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

How long will it take?

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

What is the difference between a master file and a local file?

The master file describes the group as a whole — its structure, where value is created, how intangibles and financing are held. The local file covers one entity's own related-party transactions in detail, with the analysis supporting each price. Larger groups file both, plus country-by-country reporting above a size threshold, and the thresholds differ by country. See master file vs local file.

Do we need transfer pricing documentation for a small group?

The obligation follows the existence of cross-border transactions with related parties, not the size of the group — which surprises founders with one foreign subsidiary and a management fee. Size affects which report is required: a local file, a master file, a country-by-country report. In Canada the practical trigger is timing, because documentation prepared by the filing due date is what stands between an adjustment and a penalty on top of it. See contemporaneous documentation in Canada.

What is OECD Pillar Two?

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

Is the quote binding?

Yes, for the scope quoted. A change in scope is re-quoted before the work continues, so there is never an invoice you have not already agreed to.

What if I disagree with the position you recommend?

We set out the alternatives with their exposure and let you choose. Where a position is defensible but aggressive we say so in writing rather than filing it quietly.

Tax terms explained

Reassessment noticeCredit methodCustoms valuationUnified creditFixed place of businessVoluntary Disclosures ProgramService PEPlace of supplySection 217Section 195 TDSDual-status alienLiaison officeResale price methodCountry-by-country report Browse the full A–Z glossary

Related pages

Related in this section

All transfer pricingRoyalty rate studyLocal fileChoosing a method — CUPCountry-by-country reportProfit split methodBusiness restructuring & exit charges

Adjacent services

Indian withholding on software paymentsReporting crypto on T1135Exit strategy for foundersIndependent agent and permanent establishment — international taxTrusts before becoming a residentCrypto for corporations

Answered questions

Do I need TP adjustments & secondary adjustments?
Fixed fee agreed before we start

Talk to us about tp adjustments & secondary adjustments

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

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Re-quoted, never silently invoiced
  • Your existing accountant keeps the domestic file
  • 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.

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