Value-priced TP audit defence file

A defence file is not the documentation report. Value-priced TP audit defence file with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

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

24-hour helpline: +1 (416) 619-0068
  • Fixed fee agreed before work starts
  • Offices in India, the USA, Canada and the UAE
  • 15+ years of cross-border experience
The short answer

A defence file is not the documentation report. Assembling it before an audit means the response is a document delivery rather than a reconstruction.

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

What tp audit defence file costs here

A defence file is priced on what already exists. Where intercompany agreements, invoices, board minutes and time records can be pulled from the system for the years under review, assembling them is orderly work; where the people who set the policy have gone and the evidence has to be reconstructed, it is a longer engagement.

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, quoted before work starts

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

TP benchmarking study — fixed-fee price

From $2,500

fixed, quoted before work starts

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

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

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

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

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

All published fees on one page — all of it on a single page, so the number you compare is the number you pay.

How the rule actually works

A defence file is not the documentation report. It is the evidence behind it — the emails, time records, board minutes and invoices that show the conduct matched the policy.

Assembling it before an audit means the response is a document delivery rather than a reconstruction. The file also identifies the weak points in advance, which is what makes a settlement position realistic.

The consequence is that TP audit defence file is rarely won or lost on the return itself. It is decided by whether the right document existed at the right moment, and by whether the two countries were dealt with in the order that makes the relief usable rather than merely claimable.

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 US sales tax nexus for foreign sellers and outbound investment (odi) from India.

What we actually file

  • 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 defence file of the evidence behind the documentation

A worked example

The arithmetic is more persuasive than the description, so:

An operating margin against a tested range

A limited-risk entity with C$29,000,000 of revenue reporting a 1% operating margin. Assume a benchmarking study produced an interquartile range of 4% to 7%.

An operating margin against a tested range
ItemAmount
RevenueC$29,000,000
Operating margin reported1%
Operating profit reportedC$290,000
Assumed tested range4% – 7%
Profit at the bottom of the rangeC$1,160,000
Potential adjustmentC$870,000

A margin below the range invites an adjustment of C$870,000 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.

An illustration, not a client file. The sums are chosen for legibility and the thresholds are stated for the example alone — nothing reaches a filing until it has been confirmed at source for your own year.

What working with us looks like

  1. 1We establish what happened and when, because every position here is anchored to a date
  2. 2A written scope and a fixed price, so you know the cost before committing
  3. 3The filings are prepared, cross-checked against each other, and reviewed by name
  4. 4You see the result, approve it, and we file it

Fees for this work

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 named reviewer signs off every statutory filing.
  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Consultations scheduled to your working day rather than ours.

How to get this moving

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 audit defence file engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

Where transfer pricing tax comes into this file

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

A defence file is not the documentation report.

From first contact to filed return

  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.

How tp audit defence file 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

The vocabulary this page leans on

Terminal return
The final income tax return of a deceased person, covering income to the date of death and the deemed dispositions arising on it.
Paid-up capital
The tax-recognised capital of a corporation, which determines how much can be returned to shareholders without a deemed distribution.
QEF election
An election to treat a foreign pooled investment as a qualified electing fund, taxing its income currently instead of under the default throwback regime.
Black Money Act
India's statute on undisclosed foreign income and assets, with its own assessment powers, penalties and prosecution provisions outside the income tax act.
tp audit defence file: The practitioner's note

Assembling it before an audit means the response is a document delivery rather than a reconstruction.

However the file develops, three things stay fixed: a written scope and fee before work begins, a named practitioner reviewing the result, and your approval before anything is filed.

The published fees closest to tp audit defence file

Building the file before a query arrives is a smaller job than building it during one, because an audit sets the pace and the weak points get found by someone else first. Scope is the other factor: the number of transaction streams and open years the file has to cover. The fee is fixed in writing at the start.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

Covers: Registrations, withholding and the employer obligations that follow staff working across a border, set up once and correctly.

See this fee page

The difference a dedicated cross-border team makes

The fee is fixed before we start

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

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

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.

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 team reviewing a file together at a desk

Tp audit defence file — the four phases

Step 1

Initial call

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

Step 2

Scope and fee

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

Step 3

Preparation and review

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

Step 4

Filing and payment

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

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

How the work runs — quote first, then the work

  • 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

Keep reading, sideways

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

Graduated rate estates Everything on graduated rate estates, at the same depth as this page.
Regulation 105 — waiver application Regulation 105 waiver application — the guide, the FAQ and the fixed fee.
US sales tax nexus for foreign sellers The full guide to US sales tax nexus for foreign sellers, with the fee fixed before any work starts.
Step-up in cost base on arrival Its own page: step-up in cost base on arrival — mechanism, deadlines and published fees.
Form 5173 — transfer certificate Everything on form 5173 transfer certificate, at the same depth as this page.
Local resident director services in Canada Resident director services Canada — the guide, the FAQ and the fixed fee.
Form T106 — non-arm's-length transactions The full guide to t106 non arms length transactions, with the fee fixed before any work starts.
Cross-border charity and donation relief Its own page: cross-border charity and donation relief — mechanism, deadlines and published fees.
ESOP taxation for Indian employees of foreign parents Everything on ESOP taxation for Indian employees of foreign parents, at the same depth as this page.

Clients who arrive with this exact page

Professional services firms cross-border tax Everything on professional services firms cross border tax, at the same depth as this page.
Civil & structural engineers — relief you're probably missing Civil & structural engineers relief you're probably missing — the guide, the FAQ and the fixed fee.
Amazon FBA sellers — relief you're probably missing The full guide to amazon fba sellers relief you're probably missing, with the fee fixed before any work starts.
Tax for crypto traders Its own page: crypto traders tax — mechanism, deadlines and published fees.
Shopify & DTC brands cross-border tax Everything on shopify & dtc brands cross border tax, at the same depth as this page.
Law firms cross-border tax Law firms cross border tax — the guide, the FAQ and the fixed fee.
Amazon FBA sellers — what we charge The full guide to amazon fba sellers what we charge, with the fee fixed before any work starts.
Education & ed-tech cross-border tax Its own page: education & ed-tech cross border tax — mechanism, deadlines and published fees.
Tax for architects Everything on architects tax, at the same depth as this page.

The corridors we work every week

Austria tax for expats — country guide Everything on Austria tax for expats, at the same depth as this page.
South Africa tax for expats — country guide South Africa 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.
Tanzania tax for expats — country guide Its own page: tanzania tax for expats — mechanism, deadlines and published fees.
Sweden tax for expats — country guide Everything on Sweden tax for expats, at the same depth as this page.
United Kingdom tax for expats — country guide United Kingdom tax for expats — the guide, the FAQ and the fixed fee.
Seychelles tax for expats — country guide The full guide to seychelles tax for expats, with the fee fixed before any work starts.
Nigeria tax for expats — country guide Its own page: Nigeria tax for expats — mechanism, deadlines and published fees.
Cyprus tax for expats — country guide Everything on Cyprus tax for expats, at the same depth as this page.

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

A Pricing Study That Started With Who Does What

Functions, assets and risks decide which entity should earn the return, and the method follows from that rather than the other way round. Getting the sequence backwards is how a study fails on its first question.

Read how this one runs
Case study 2

An Adjustment in One Country and No Relief in the Other

A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.

Read how this one runs
Case study 3

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 4

The Local File That Has to Match the Accounts

A local file describes the entity's own controlled transactions and ties them to its statutory figures. Where the two do not reconcile, that is what an examiner opens with.

Read how this one runs
Case study 5

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 6

Green Card Kept, Moved to Canada — Both Returns Still Due

Holding a green card does not end the US filing obligation, and living in Canada starts a Canadian one. The engagement fixes residence under the treaty tie-breaker, then decides which return the relief is claimed on so the two do not contradict each other.

Read how this one runs
Case study 7

A Canadian Landlord With Property in the United States

Gross withholding on US rents takes no account of mortgage interest, tax or repairs, so a leveraged property can face tax on turnover. An election onto net basis fixes that, and it has its own timing and its own filing.

Read how this one runs
Case study 8

Withheld at the Statutory Rate When a Treaty Rate Applied

Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

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

U.S. & Cross-Border Tax Returns

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

Expat & Emigration Tax

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

Non-Resident Canadian Tax

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

Transfer Pricing & BEPS

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

Cross-Border Estates & Trusts

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

Cross-Border Corporate Tax

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

India Tax for NRIs & Returning Residents

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

Canadian Tax with a Foreign Element

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

UAE Tax for Expats & Their Home Country

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

Industries & Client Types We Serve Worldwide

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

Global E-commerce & Marketplaces

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

Technology & SaaS

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

Importers, Exporters & Manufacturers

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

Athletes, Artists & Entertainers

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

Remote Workers & Digital Nomads

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

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

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

Investment Funds & Holding Companies

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

TP audit defence file — questions we are asked

TP audit defence file — do I need an adviser, or can I do it alone?

Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: assembling it before an audit means the response is a document delivery rather than a reconstruction.

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.

Is "fund transfer pricing" the same thing as transfer pricing?

No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.

What is an intercompany agreement, and do we need one?

It is the contract between the related parties — who does what, who bears which risk, what is charged and on what basis. It matters because when there is no agreement, an auditor prices the transaction from the conduct they can observe rather than from the arrangement you intended, and conduct rarely tells the whole story. Signed agreements that match the invoices and the actual functions are the cheapest transfer pricing protection there is. See our transfer pricing work.

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.

When do I pay?

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

Why do you not publish more numbers on the site?

Because thresholds and rates move, and a stale figure on a page is the one that gets copied into a filing. Where we can verify a figure for the year we publish it with its source; where we cannot, we explain the mechanism instead.

15+ years of cross-border experience

Tp audit defence file, quoted before we start

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

  • Re-quoted, never silently invoiced
  • Rated 5.0 out of 5 stars on Google
  • 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