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Intra-Company Transfers: Canada vs. the US vs. the UK

Rakhmad Sobirov Rakhmad Sobirov Managing Lawyer Last updated: 11 mins read

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Quick answer

Choose Canada when your transferee’s family and long-term future matter: spouses of workers in TEER 0 or 1 jobs can get an open work permit, and skilled work in Canada can count toward permanent residence through Express Entry. Choose the US when the US market is the priority, keeping in mind that L-1 status is temporary, capped at 7 years (L-1A) or 5 years (L-1B), with only a one-year initial stay for a new office. Choose the UK for a base near Europe if you can meet a salary floor of £52,500 or the going rate, whichever is higher, accepting that the Senior or Specialist Worker visa does not lead to settlement.

Side by side

Side-by-side comparison

Here is how the three main intra-company transfer routes compare on the points employers ask about most. The Canadian column is our focus; US and UK details come directly from USCIS and GOV.UK guidance.

Factor Canada ICT US L-1 UK Senior or Specialist Worker
Eligible roles Executives and managers (C62), specialized knowledge workers (C63), and staff sent to open a new Canadian office (C61) Executives and managers (L-1A) and specialized knowledge employees (L-1B) Senior managers and specialist employees in a job on the list of eligible occupations
Minimum time with the company At least 1 year full-time with the company abroad in the previous 3 years; part-time work does not count 1 continuous year with a qualifying organization abroad in the 3 years before admission 12 months with the employer outside the UK; no minimum if paid £73,900 a year or more
Salary requirement Specialized knowledge (C63): at least the prevailing wage for the region No salary threshold set out on the USCIS L-1 pages At least £52,500 a year or the going rate for the job, whichever is higher
Opening a new office Yes (C61), if the company is already a multinational; secured premises, staffing plan and financial capacity required; 1-year permit Yes; secured physical premises required; initial stay of 1 year Separate route: UK Expansion Worker visa, for a business not yet trading in the UK; 2 years maximum
Maximum stay 7 years for executives and managers; 5 years for specialized knowledge (initial permit up to 3 years) 7 years (L-1A); 5 years (L-1B); initial stay up to 3 years 5 years in any 6; 9 years in any 10 if paid £73,900 or more
Spouse can work? Yes, with an open work permit if the transferee is in a TEER 0 or 1 job (or a listed TEER 2 or 3 job) with at least 16 months left on their permit Yes; L-2 spouses are work-authorized incident to status Yes; dependant partners can work (except as a sportsperson or coach)
Children Not eligible for open work permits under the family policy since January 21, 2025 Unmarried children under 21 can come in L-2 status Children under 18 can apply as dependants
Path to permanent residence Not automatic, but skilled Canadian work can count toward the Canadian Experience Class and other Express Entry and PNP routes L-1 is a temporary status; US green card options require separate advice from US counsel Does not lead to settlement (indefinite leave to remain)
Typical processing 2-week target under the Global Skills Strategy for eligible TEER 0 or 1 applications made online from outside Canada Varies; see current USCIS processing times Usually 3 weeks from outside the UK; 8 weeks from inside
Government fees $155 work permit fee and $230 employer compliance fee; $100 open work permit holder fee for a spouse; biometrics from $85 Several USCIS fees apply to Form I-129; see the G-1055 Fee Schedule £819 (up to 3 years) or £1,618 (over 3 years) from outside the UK, plus a health surcharge of usually £1,035 a year

Figures checked on official government pages on October 20, 2026. Rules and fees change often, so confirm before you file. Canadian fees are in CAD.

Canada advantages

When Canada is the stronger choice

Canada tends to win when the transfer is part of a longer plan for the employee and their family.

  • A route to permanent residence

    Skilled work in Canada (TEER 0, 1, 2 or 3) can qualify for the Canadian Experience Class after 1 year in the last 3 years, and Express Entry candidates can also receive a provincial nomination.

  • Work rights for spouses

    Spouses and common-law partners of transferees in TEER 0 or 1 jobs can apply for an open work permit if the transferee’s permit has at least 16 months left.

  • Free trade agreement options

    CUSMA, CETA and CPTPP each have intra-corporate transferee categories that IRCC applies alongside the regular ICT rules.

  • Two-week processing target

    Under the Global Skills Strategy, IRCC aims to process eligible TEER 0 or 1 applications made online from outside Canada within 2 weeks. It is a target, not a guarantee.

Other options

When the US or UK may fit better

We are Canadian immigration lawyers. For US and UK filings, we coordinate with licensed counsel in those countries. The points below come only from official USCIS and GOV.UK guidance.

01

The US market is your priority

US L-1

Why it fits

A foreign company with no US office can send an executive or manager to open one under L-1A, and L-2 spouses are authorized to work.

Keep in mind

A new-office stay starts at 1 year, and the US office must support an executive or managerial role within 1 year of approval.

02

You already run a large US operation

Blanket L

Why it fits

Groups with a US office doing business for 1 year or more, 3 or more related entities, and 10 L-1 approvals in 12 months, $25 million in US sales or 1,000 US staff can use a blanket L petition.

Keep in mind

A blanket approval does not guarantee L-1 classification for each employee.

03

You need a base near Europe

UK

Why it fits

Employees paid £73,900 or more need no minimum time with the company and can stay up to 9 years in any 10.

Keep in mind

The salary floor is £52,500 or the going rate, whichever is higher, and the visa does not lead to settlement.

04

You are opening a first UK branch

UK Expansion

Why it fits

The UK Expansion Worker visa lets a senior manager or specialist set up a UK branch of a business that is not yet trading there.

Keep in mind

The maximum stay is 2 years and the route does not lead to settlement.

Expansion

Opening a new office in each country

Canada (C61). The foreign company must already be a multinational with revenue-generating operations in at least one country other than its home country; it cannot use an ICT to open its first foreign office. The transferee must show the company has secured, or is entering Canada to secure, physical commercial premises, has reasonable staffing plans, and has the financial ability to start and run the Canadian business. The first permit is limited to 1 year. See the new Canadian office category in our ICT guide.

United States (L-1 new office). The employer must have secured sufficient physical premises for the new office. For L-1A, the transferee must have worked as an executive or manager for 1 continuous year in the 3 years before filing, and the US office must support an executive or managerial role within 1 year of approval. For L-1B, the employer must show it can pay the employee and begin doing business in the US. The initial stay is 1 year.

United Kingdom (UK Expansion Worker). This Global Business Mobility route is for a senior manager or specialist employee sent to set up a UK branch of an overseas business that has not started trading in the UK. The worker needs 12 months with the employer outside the UK unless an exception applies, such as earning over £73,900, and must be paid at least £52,500 or the going rate, whichever is higher. The first stay is up to 12 months, with extensions to a 2-year maximum.

What changed

Canada's 2024–2025 ICT changes in brief

  • Free trade agreement rules rewritten (October 2024)

    IRCC released extensive updates to its free trade agreement instructions on October 1, 2024, then revised the CETA and CUKTCA transferee instructions on May 2, 2025, removing the word “senior” from the manager description.

  • Multinational test clarified (January 2025)

    IRCC’s updated ICT instructions explain how officers assess whether a company is a multinational under C61, C62 and C63. A company cannot use an ICT to open its first foreign office.

  • Spousal open work permits narrowed (January 21, 2025)

    Only spouses of workers in TEER 0 or 1 jobs, or listed TEER 2 or 3 jobs, with at least 16 months left on their permit now qualify. Dependent children no longer qualify.

Common questions

Intra-company transfers: frequently asked questions

Is the Canadian ICT easier than the US L-1?

Neither is simply easier. Both require a qualifying corporate relationship and at least 1 year of work for the company abroad in the last 3 years. Canada adds a multinational test and, for specialized knowledge roles, a prevailing-wage floor. On the other hand, Canada offers open work permits for spouses of TEER 0 or 1 workers and a 2-week processing target for eligible applications. Which route is easier depends on your corporate structure and the role.

Can an L-1 holder transfer to Canada?

Yes, but L-1 status does not carry over. The employee needs a Canadian work permit, such as an ICT, and must meet Canada’s rules on their own, including at least 1 year of full-time work in the previous 3 years for a related company outside Canada. Time with a related US company can count if it meets IRCC’s requirements.

Do UK Global Business Mobility workers get settlement?

No. GOV.UK states that holders of the Senior or Specialist Worker visa and the UK Expansion Worker visa cannot apply to settle permanently (indefinite leave to remain) on those visas.

Can a small company use an ICT in Canada?

Size alone does not decide it. The company must be a multinational with revenue-generating operations in at least one country other than its home country, and the Canadian entity must be large enough to support the executive, managerial or specialized role for the length of the permit. If you own and control the business yourself, compare the options in our C11 vs ICT guide.

How long does each take?

Canada: IRCC aims to process eligible Global Skills Strategy applications (TEER 0 or 1 jobs, applied online from outside Canada) within 2 weeks. For real-world timelines by applicant country, see our guide to ICT work permit processing times from the US, UK and India. UK: GOV.UK says decisions usually take 3 weeks from outside the UK and 8 weeks from inside. US: timing varies; check the current USCIS processing times and speak with US counsel.

About the author

Rakhmad Sobirov
Rakhmad Sobirov

Rakhmad is the Managing Lawyer and co-founder of Sobirovs Law Firm. He was called to the Ontario bar in 2012 and leads the firm’s business immigration practice for entrepreneurs, investors and multinational companies, including Intra-Company Transfers, C11 work permits and Provincial Nominee Program entrepreneur streams. Before founding the firm, he worked on aerospace contracts and compliance at Bombardier and at Bird & Bird. He works with clients in English, Russian, Turkish, Uzbek and Tajik.

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