6 worked Transfer Pricing Benchmarking case studies — the position a client typically comes to us with, what we do, and what it is worth. Each is an illustrative example built on the rules that apply to transfer pricing benchmarking work, not a specific client's file.
Case Study 1 · Scaling without breaking
Second-Province Expansion Handled, $55,000 Of Cash Released — Inbound Assignee, Winnipeg
Client: An inbound transferee on assignment · Where: Winnipeg, Manitoba · Engagement: 5 weeks, fixed fee
Cash released$55,000
New registrationsComplete on day one
Compliance gapsNone
The situation — An inbound transferee on assignment, Winnipeg, Manitoba
Revenue at an inbound transferee on assignment in Winnipeg, Manitoba was up sharply and cash was tighter than ever. Underneath it sat US tax paid but no foreign tax credit claimed on the Canadian return.
What we did for An inbound transferee on assignment, Winnipeg, Manitoba
We registered the payer for a non-resident withholding account, remitted the Regulation 105 amounts due, and applied for waivers covering the rest of the contract. Every new obligation — registration, remittance frequency, provincial filing — was set up before it was triggered, not after.
The result — An inbound transferee on assignment, Winnipeg, Manitoba
$55,000 of cash was released from the working capital cycle, and the expansion completed with every registration and filing obligation covered from day one.
Case Study 2 · Backlog brought current
3 Years Filed, $37,000 Removed From The Assessed Balance — US-Facing Canadian Corporation, Moncton
Client: A Canadian corporation with US customers · Where: Moncton, New Brunswick · Engagement: 7 weeks, fixed fee
Years filed3
Assessed balance removed$37,000
CollectionsStopped
The situation — A Canadian corporation with US customers, Moncton, New Brunswick
A Canadian corporation with US customers in Moncton, New Brunswick had not filed for 3 years. The CRA had issued arbitrary assessments, and the business was carrying a departure year filed as a normal resident return with no deemed disposition reported on top of a growing interest balance.
What we did for A Canadian corporation with US customers, Moncton, New Brunswick
We started with the oldest year and worked forward so each year's closing balances fed the next. We reconstructed the day count on both sides of the border and documented the residency and treaty position before either revenue authority asked, filing the years in sequence rather than all at once.
The result — A Canadian corporation with US customers, Moncton, New Brunswick
Every year is now filed and assessed on actual figures. The notional assessments were vacated and $37,000 of the estimated balance came off, with a payment arrangement covering the rest.
Client: A Canadian corporation operating a US branch · Where: Surrey, British Columbia · Engagement: 9 weeks, fixed fee
Amount recovered$118,000
Reporting statusCurrent
Annual effortHours, not weeks
The situation — A Canadian corporation operating a US branch, Surrey, British Columbia
Foreign holdings at a Canadian corporation operating a US branch in Surrey, British Columbia had passed the reporting threshold without anyone noticing. Behind the disclosure problem sat 25% withholding on gross Canadian rent where a section 216 election would have taxed only the net.
What we did for A Canadian corporation operating a US branch, Surrey, British Columbia
We filed the outstanding T1135 disclosures through the Voluntary Disclosures Program, which eliminated the penalty exposure entirely, claiming the treaty relief and foreign tax credits on the Canadian return and correcting the disclosure position for the open years.
The result — A Canadian corporation operating a US branch, Surrey, British Columbia
The treaty position was accepted and $118,000 was recovered. Reporting is now current and the annual process takes hours rather than weeks.
Client: A non-resident owning Canadian rental property · Where: Kelowna, British Columbia · Engagement: 10 weeks, fixed fee
Penalty cancelled$38,000
Relief applicationGranted
ReturnAccepted as filed
The situation — A non-resident owning Canadian rental property, Kelowna, British Columbia
A non-resident owning Canadian rental property in Kelowna, British Columbia had already missed one deadline and was about to miss a second. Behind it sat a US LLC taxed as a corporation in Canada, producing double tax on the same income, and a penalty of $38,000 was accruing.
What we did for A non-resident owning Canadian rental property, Kelowna, British Columbia
We split the work into what had to happen before the deadline and what could follow it, then filed the section 216 election with the supporting rental statements and recovered the excess withholding as a refund.
The result — A non-resident owning Canadian rental property, Kelowna, British Columbia
The outstanding return was accepted as filed, and the taxpayer relief application cancelled $38,000 of the penalty already assessed on the earlier year.
Case Study 5 · Sale and succession
Share Sale Restructured, $275,000 Less Tax On Closing — Florida Property Owner, Saskatoon
Client: A family with a Florida vacation property · Where: Saskatoon, Saskatchewan · Engagement: 4 weeks, fixed fee
Tax saved on closing$275,000
PriceAs agreed
Post-closing adjustmentsNone
The situation — A family with a Florida vacation property, Saskatoon, Saskatchewan
A family with a Florida vacation property in Saskatoon, Saskatchewan was preparing to sell. Due diligence surfaced a single shareholder holding every share, with no room to multiply the exemption, which would have reduced the price or killed the deal outright.
What we did for A family with a Florida vacation property, Saskatoon, Saskatchewan
We cleaned up the historical file, applied the treaty rate to the dividend withholding, filed the NR4 return, and remitted the shortfall before the CRA assessed the payer for it, and prepared the due-diligence package the buyer's advisers actually asked for.
The result — A family with a Florida vacation property, Saskatoon, Saskatchewan
The deal closed at the agreed price. $275,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.
Case Study 6 · Planning that cut the bill
$24,500 Saved By Correcting What Prior Filings Had Missed — Mid-Year Emigrant, Lethbridge
Client: An emigrant who left Canada mid-year · Where: Lethbridge, Alberta · Engagement: 3 weeks, fixed fee
Saving identified$24,500
RecurringYes
Positions documentedAll
The situation — An emigrant who left Canada mid-year, Lethbridge, Alberta
An emigrant who left Canada mid-year in Lethbridge, Alberta asked for a second opinion on transfer pricing benchmarking after three years of rising tax. The review found winters spent in the United States with the day count kept casually and no residency position documented anywhere.
What we did for An emigrant who left Canada mid-year, Lethbridge, Alberta
We built the comparison first — current structure against two alternatives — and then aligned the Canadian and US reporting of the same income so the foreign tax credit claim carried support on both returns.
The result — An emigrant who left Canada mid-year, Lethbridge, Alberta
First-year saving of $24,500, with the same benefit recurring. Every position taken is documented and supported in the file.
Reviewed for the 2025 tax year by Udit Gupta, Founder and Tax Accountant. These case studies are illustrative worked examples composed from the CRA rules that apply to this type of work, not specific client files; figures are representative and outcomes depend on your own facts.
