Transfer Pricing Services in Canada That Hold Up Under CRA Review
Bestax prices, documents, and defends your related party transactions under Canadian and OECD transfer pricing rules.
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Trusted by businesses across Canada to stay compliant, organized and financially confident.
Everything We Handle for Your Related Party Transactions
Every intercompany transaction you run creates a compliance obligation. Our transfer pricing services in Canada cover each one, as shown below.
Service: Transfer pricing studyWhat We Do: Benchmark your transactions against comparable market data
Service: DocumentationWhat We Do: Prepare contemporaneous files under Canadian rules
Service: Policy designWhat We Do: Set pricing methods for goods, services and intangibles
Service: T106 and CbCR filingsWhat We Do: Prepare and file required information returns
Service: Audit defenceWhat We Do: Respond to CRA queries with your prepared file
Benchmarking Studies That Prove Your Pricing
Every transfer pricing study we prepare in Canada tests your intercompany prices against real market prices. We analyze your functions, assets, and risks for each transaction. We then benchmark comparable company data against your actual results. The final study documents the chosen method and why it fits. You receive a report you can hand directly to the CRA or an auditor. The arm's length principle sits at the core of every study we prepare.
Files That Exist Before the CRA Ever Asks
Canadian rules require contemporaneous records for related party transactions. Our Canadian transfer pricing documentation describes your transactions, terms, participants, and pricing methods. We complete and date files before your filing deadline, not after the CRA sends a letter. Each year we refresh the file so it tracks your actual operations. Missing documentation exposes you to penalties, so we build yours first.
One Pricing Policy Applied Across Every Entity
Your policy decides how goods, services, royalties, and loans are priced between entities. We design methods that follow the OECD approaches recognized by the CRA. Pricing for intercompany financing arrangements is covered under the same framework. You receive a written policy your finance team can apply to every new transaction.
Your T106 and Reporting Filings, Reconciled
Canadian taxpayers must file the T106 information return for reportable transactions with related nonresidents. We prepare your T106 forms and reconcile them against your documentation. Where Country-by-Country Reporting applies, we prepare those filings too. Your returns and your files always tell the same story.
CRA Audit Defense and Dispute Support
CRA transfer pricing reviews start with a documentation request. We respond using the file we already built for you. Our team supports you through queries, proposed adjustments, and objections. Everything we submit traces back to your benchmarked study.
The Canadian Rules We Work Against
Specific legal requirements govern Canada's transfer pricing. We build every engagement around the official rules below.
| Requirement | Official Rule | How Bestax Handles It |
|---|---|---|
| Arm's length pricing | Section 247 of the Income Tax Act requires market-based pricing between related parties | Every transaction is benchmarked against comparable market data |
| Contemporaneous documentation | Records must describe transactions, terms and methods completely and accurately. | Files are prepared and dated before your filing deadline |
| T106 reporting | Reportable transactions with related nonresidents require a T106 return | We prepare T106 forms reconciled to your documentation |
| Accepted methods | The CRA accepts the methods in the OECD Transfer Pricing Guidelines | We select and justify the method that fits each transaction |
How We Deliver a Transfer Pricing Engagement
Scoping call.
You describe your group structure, transactions, and jurisdictions. We identify which obligations apply.
Written scope and fee.
We confirm deliverables, timeline, and cost in writing. Nothing starts before your approval.
Functional analysis.
We interview your team and map functions, assets, and risks. This analysis anchors the method selection.
Benchmarking.
We gather and screen comparable company data for your transactions. Results are tested against your actual margins.
Documentation and review.
We draft the study and files, then a senior reviews them. You see the conclusions explained in plain terms before anything is finalized.
Filing and monitoring.
We file T106 and related filings on schedule. We refresh your documentation each year as operations change.
When Two Tax Authorities Look at the Same Transaction
Cross-border transfer pricing gets harder when two tax authorities examine the same transaction. We prepare documentation that holds up on both sides of the border. Our Dubai office, Bestax Chartered Accountants, handles UAE transfer pricing under the UAE corporate tax regime. Groups operating in Canada and the UAE get one coordinated file instead of two conflicting ones. Where foreign tax is paid on the same income, our foreign tax credit service recovers the overlap. You can read how those credits work in our foreign tax credit guide.
Why Businesses Bring Their Transfer Pricing to Bestax
Working with one transfer pricing consultant in Canada keeps your studies, files, and returns consistent. Here is what that looks like in practice.
Documentation comes before disputes.
We build contemporaneous files ahead of deadlines, not after CRA letters. Your defense exists before any question is asked.
Studies and filings always match.
The same team prepares your study, documentation, and T106 returns. The CRA never finds contradictions.
Two offices cover both sides.
Our transfer pricing experts in Canada and Dubai work as one team. We manage Canada and UAE obligations as a single engagement.
Transfer pricing connects to your other filings.
Results flow into your T2 corporate tax return and international tax planning. One firm keeps every filing consistent.
Fees are fixed in writing.
You approve the engagement fee before work begins. We agree to scope changes in writing first.
Our Success Stories
One of the best firm I have dealt with in Ontario. Bestax supported my corporate tax filing perfectly and even answered my silly questions without getting irritated. Love the personal touch they add to service.
Google review 1 of 4: zahra sabilaputri
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Frequently Asked Questions About Bestax
We prepare transfer pricing studies, contemporaneous documentation, policies, T106 filings, and audit defense. One team handles cross-border engagements covering Canada and the UAE. We confirm the scope in writing before work begins.
Yes. Our files fully describe your transactions, terms, participants, and methods. We prepare and date documentation before your filing deadline.
Yes. Our Dubai office, Bestax Chartered Accountants, manages UAE transfer pricing requirements. We prepare Canadian and UAE files as one coordinated engagement.
Yes. We prepare T106 forms for reportable transactions with related nonresidents. We reconcile each form against your documentation before filing.
We respond using the study and files we already prepared. Our team supports you through queries, adjustments, and objections.
We apply the OECD methods the CRA accepts. We select and justify the method for each transaction in your study.
Fees depend on the number of transactions, entities, and jurisdictions involved. You receive a fixed written fee after the scoping call.
Book a consultation online, call +1 416 991 0900, or email info@bestax.ca. We scope your obligations and send a written engagement plan.