Guarantee fee estimator
Price an intragroup guarantee from the interest saving it produces.
Open itThe three-tier documentation standard is the same everywhere; the thresholds are not. Enter the figures for your group and the thresholds your jurisdictions actually use, and this tells you which tiers are triggered and by how much.
Your group and your thresholds
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For the reporting period the thresholds are tested on, which is usually the preceding year.
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For the entity you are testing, in the same currency as the thresholds you enter.
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The consolidated revenue figure your jurisdiction uses. Enter it in your own currency.
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Where your jurisdiction sets one. Leave at zero if it does not use a group revenue test.
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Where your jurisdiction sets one. Leave at zero if it does not.
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The figure above which a local file is required for the entity.
Some regimes require both limbs, some only one. Check yours.
Tiers triggered
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How many of the three —
Local file —
Master file —
Country-by-country report —
Headroom below the local file threshold—
Headroom below the master file transaction threshold—
Headroom below the master file group threshold—
Headroom below the country-by-country threshold—
Three tiers, three audiences
The local file describes the entity: its controlled transactions, the method chosen, the comparables and the financial data supporting the result. It is what a local auditor reads first. The master file describes the group: the structure, where the intangibles sit, how the group finances itself and the intercompany financial arrangements. The country-by-country report is a table of revenue, profit, tax paid, employees and assets by jurisdiction, filed by the ultimate parent and exchanged between authorities.
The thresholds are set locally, and no two jurisdictions agree. That is why every threshold in this tool is a field you fill in rather than a number the calculator supplies. A group operating in four countries can easily be inside the local file requirement in three of them and the master file requirement in one.
Being under a threshold is not being out of scope
Falling below the documentation thresholds removes a filing obligation, not the arm's length requirement. The pricing still has to be arm's length, an authority can still ask how it was set, and penalty protection in most regimes is only available where contemporaneous documentation exists. A group under every threshold and holding nothing on paper has the same exposure and none of the mitigation.
Deadlines vary too, and they are usually earlier than people expect: several regimes require the local file to exist by the time the return is filed, and the country-by-country notification well before the report itself is due.
Worked example
A group with 900 million of consolidated revenue and a local entity with 40 million of international related-party transactions, tested against thresholds of 750 million, 500 million, 50 million and 10 million.
- Group revenue is over the country-by-country threshold, so that report is due from the parent.
- Group revenue is over the master file group limb, but the 40 million of transactions is under the transaction limb — so on a both-limbs test the master file is not triggered.
- The 40 million is well over the local file threshold, so the local file is required.
Switch the combination test to either and the master file comes into scope immediately. That single dropdown is the difference between two documents and three.
What this calculator assumes
- Every threshold is a figure you enter. No jurisdiction’s threshold is asserted here, because they differ and they move.
- Currency conversion is not handled. Enter the group figures and the thresholds in the same currency.
- Only the three main tiers are tested. Country-by-country notifications, local disclosure forms and accountant certificates are additional obligations in several jurisdictions.
- Being under a threshold removes a filing obligation, not the arm’s length requirement or the value of documentation for penalty protection.
An estimate, not advice. This is an estimate built from what you typed, not advice on your file. Nothing here reads your documents, checks your treaty article or looks at the year you are actually in. Where the number matters, we agree a fixed fee in writing before any work starts.
Where these figures come from
- current guidance OECD — country-by-country reporting and Action 13
- current guidance Canada — country-by-country reporting, CRA
- current guidance India — transfer pricing documentation, Income Tax Department
Any figure prefilled in the panel above is stated with the year it belongs to and can be changed. Rates and thresholds move; a calculator that asks you for the current one stays right, and one that hides a guess does not.
Cross-border tax case studies
Case study 1
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 2
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 3
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 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
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 6
One Salary, Two Countries Claiming It
A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.
Read how this one runs
Case study 7
Paying a Beneficiary Who Lives Abroad
Distributions to a non-resident beneficiary carry withholding and a designation that decides its rate. Getting the designation right before the payment avoids recovering the difference through a return afterwards.
Read how this one runs
Case study 8
A Clean History Used to Remove a First Penalty
An administrative waiver can remove a first failure where the filing and payment record supports it, and it is spent once used. Whether to claim it now or keep it for a heavier year is a judgement made with the whole file in view.
Read how this one runsAll 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.
Tax Treaties & Withholding
Relief is only as good as the paperwork claiming it — we build treaty positions that survive review on both sides.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Global Investments & Reporting
Information returns carry the sharpest penalties — $25 a day whether or not any tax is owing. We keep them clean and on time.
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
Who We Serve:
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Who We Serve:
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Who We Serve:
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Who We Serve:
Importers, Exporters & Manufacturers
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Who We Serve:
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Who We Serve:
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Who We Serve:
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
Who We Serve:
