Numerous related matters may arise from or independently from transfer pricing. These are treaty-based matters that must be addressed to provide relief of double taxation. DRTP Consulting provides services on treaty-based requests, returns and waivers.


DRTP Consulting offers services on treaty-based requests, returns and waivers. DRTP Consulting services are relevant to any business involved in international commerce. DRTP Consulting services are also relevant to accounting and legal firms which assist their clients with transfer pricing, tax treaties and other international tax matters.

Treaty-based requests, returns and waivers

  • Non-resident Canadian income tax matters
  • Residency matters
  • Permanent establishment matters
  • Transfer pricing adjustments
  • Double taxation of income from real property or business profits
  • Tax withheld on dividends, interests, royalties, management fees, services provided by non-residents, income from real property
  • Issues on income from interest or related to capital gains
  • Double taxation arising on income from employment, pension and annuities
  • Part XIII Tax withholding under the Canadian Income Tax Act
  • Regulations 102 and 105 withholding waivers
  • Double taxation on other types of income
  • Foreign tax credit matters

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