What business plan does an intra-company transfer (ICT) new office require?

A foreign company opening its first Canadian office can move a key employee across the border without a Labour Market Impact Assessment, using the intra-company transferee (ICT) "start-up" stream of the International Mobility Program — one of the LMIA-exempt routes on the 2026 entrepreneur immigration map. The lever that makes the file work is evidence: IRCC wants to see that the venture is real, funded, and on a path to actually doing business in Canada within a year. That evidence is anchored by a business plan. This guide maps the plan to the specific new-office criteria IRCC officers weigh under administrative code C61, and flags where the 2024 rule changes raised the bar.

What are ICT codes C61, C62, and C63?

In its 2024 revision of the intra-company transferee instructions, IRCC retired the old C12 code and replaced it with three administrative codes under paragraph R205(a) of the Immigration and Refugee Protection Regulations:

Code	Category	Who it covers
C61	ICT — Start-up Business	Transferees entering Canada to establish a new branch, subsidiary, or affiliate
C62	ICT — Executive or manager	Executives (NOC TEER 0) and managers (NOC TEER 1)
C63	ICT — Specialized knowledge	Workers with both advanced proprietary knowledge and advanced expertise

For a foreign company with no existing Canadian operation, the entry point is C61. C61 is itself available to an executive, a manager, or a specialized-knowledge employee — the code describes the purpose (establishing the new enterprise), while C62 and C63 describe ongoing occupational capacity once the business is operating. A C61 holder is expected to transition to C62 or C63 to continue working in Canada after the first year.

Does an ICT new office application need a business plan?

Yes — explicitly. IRCC's program delivery instructions list, among the C61 requirements, that the employee must:

"provide a business plan and financial documentation as evidence that the foreign enterprise has the capacity and financial ability to cover the costs to establish an enterprise in Canada as well as the costs to continue to operate the enterprise during the initial ramp-up period."

So the business plan is not a formality bolted onto the application — it is the document that carries the financial-capacity and viability case. Alongside it, the C61 applicant must:

• be at the executive or management level, or be a specialized-knowledge employee;
• be entering Canada to secure physical commercial premises for the new Canadian enterprise (the enterprise may initially use its counsel's address until a premise is purchased or leased);
• provide reasonable human resource (HR) plans to maintain or hire staff for the new enterprise — plans that demonstrate the Canadian enterprise will be large enough to support an executive, management, or specialized-knowledge function throughout the entire duration of the work permit.

What Bridge Note does on these files is build the plan so each of those four evidentiary tests is answered on the page — capacity and funding in the financial model, the hiring path in a staffing roadmap, the premises strategy in the operations section, and the role's seniority in the organizational structure. What IRCC does is weigh that evidence against the standard; the plan does not guarantee an outcome.

How does the plan map to what the officer actually weighs?

The instructions name the factors an officer considers for a new-office C61 file. A well-built plan addresses each one directly:

IRCC factor (new office, C61)	Where the plan answers it
Ownership or control of the enterprise	Corporate structure section — the qualifying relationship between foreign and Canadian entity
Commercial premises	Operations / premises plan and timeline to lease or purchase
Investment commitment	Use-of-funds and capital-injection schedule
Organizational structure	Org chart showing the role supports an executive, managerial, or specialized function
Goods or services to be provided	Business model and revenue lines
Continuing viability of the foreign operation	Foreign-entity financials and history
Financial ability to establish and support the operation	Financial projections through ramp-up; balance-sheet capacity

IRCC also requires that the new enterprise be "expected to be doing business within the first year of operation." That phrase sets the planning horizon: the financial model and milestones should show the business reaching active operations — regularly, systematically, and continuously providing goods or services — inside twelve months, not at some indefinite later date.

How long is the initial ICT new office work permit valid?

IRCC issues a C61 start-up work permit for a maximum of one year, and states that no extensions are available under this exemption code (save for rare, documented circumstances beyond the applicant's control, such as construction-permit delays).

The logic is built into the program. The instructions say:

"It is expected that within the one-year duration of the work permit issued under administrative code C61 ... the enterprise will become actively engaged in providing a good or service in Canada. As such, the applicant would transition to the executive or manager category (C62) or specialized knowledge category (C63) for any extension of work in Canada."

To make that transition, the applicant and foreign enterprise must show, at the one-year mark, that they have:

• secured physical premises for the Canadian operation;
• continued efforts to establish the enterprise; and
• the financial ability and resources to ensure the operation's viability.

This is why the new-office business plan should be written with the transition in mind, not just the initial grant. A plan that maps Year 1 milestones — premises secured by month X, first hires by month Y, first revenue by month Z — gives the officer assessing the C62 or C63 extension the demonstrated-progress evidence they need to see.

After transition, the broader ICT caps apply: executives and managers (C62) get an initial maximum of three years with two-year renewals, up to a total of seven years; specialized-knowledge workers (C63) get an initial maximum of three years with two-year renewals, up to a total of five years.

What qualifying relationship must exist between the foreign and Canadian entity?

The ICT category exists to move people within a corporate group, so the relationship between the two entities is load-bearing. IRCC requires that the Canadian and foreign enterprises be legal entities with a parent, branch, subsidiary, or affiliate relationship, established through ownership (the right of possession with full power and authority to control) and control (the right and authority to direct management and operations).

The foreign company must also be part of a multinational corporation (MNC) — defined by IRCC as a company that has revenue-generating business operations in at least one country other than its home country and that generates revenue beyond its borders. The 2024 instructions sharpened this: the foreign enterprise has to genuinely be doing business, not merely exist on paper.

• The business must be regularly, systematically, and continuously providing goods and/or services.
• An agent or office in Canada alone does not demonstrate that the enterprise is doing business.
• An enterprise with no employees that exists in name only does not qualify.

For a brand-new Canadian office, IRCC accepts that the Canadian side is not yet operating — but the applicant must provide a timeline and supporting evidence for when the new enterprise will begin doing business. The qualifying-relationship evidence (incorporation documents, ownership chain, control) sits in the corporate-structure section of the plan and its appendices.

Can the owner of a foreign company use the ICT new office stream?

This is the most common misread of C61. A founder who owns a single foreign company and wants to open a Canadian branch often assumes ICT is the route. IRCC's instructions are direct:

Foreign nationals (and/or their immediate family members) who own a controlling interest of the foreign enterprise and are seeking entry to start a new business are not eligible as an ICT unless they can demonstrate that their enterprise meets the requirements of an MNC.

In plain terms: the ICT new-office stream is for multinationals expanding, not for a single owner relocating their one company. If the foreign enterprise already operates across borders and meets the MNC test, a controlling owner may still qualify. If it does not, the owner-operator (C11) stream under the International Mobility Program — a separate category with its own ownership, viability, and duration rules — is the route to assess instead. We flag this fork early, because building a C61 plan for a file that should be an owner-operator file wastes the application.

What financial evidence does the plan need to carry?

IRCC does not publish a fixed minimum investment figure for ICT new offices. The standard is demonstrated financial capacity, not a dollar threshold. The plan and its supporting documents should evidence:

• Start-up costs — premises, equipment, professional fees, and initial hiring;
• Operating costs through ramp-up — payroll, rent, and overhead until the business is generating revenue;
• Source of funds — the foreign enterprise's balance sheet capacity to fund both the establishment and the early operation;
• Investment commitment — the capital the group is actually committing to the Canadian entity.

Because there is no published minimum, the burden is qualitative: the numbers in the model have to be internally consistent and large enough to credibly carry the business to active operations within the first year. A plan that shows a thin cash runway against an ambitious hiring schedule undercuts its own viability case. What we model is a runway that matches the staffing roadmap; what IRCC decides is whether that capacity is sufficient.

What changed in IRCC's 2024 ICT update?

The 2024 revision consolidated the intra-company transferee instructions into a single page and replaced the old C12 code with C61, C62, and C63. Two threads matter most for a new-office file:

1. A sharper "doing business" test. The instructions now spell out that the foreign enterprise must be regularly, systematically, and continuously providing goods or services, and that a name-only entity or a bare agent/office does not qualify. This tightened the multinational/qualifying-relationship requirement that anchors every ICT file.
2. Codified evidence for the new-office stream. The C61 requirements — business plan, financial documentation, HR plans sized to support the role, and premises — are set out explicitly, along with the one-year permit duration and the expectation of transition to C62 or C63.

For applicants, the practical effect is that loosely evidenced "we plan to expand to Canada" files face more friction. The plan has to do real work.

The bottom line

The ICT new-office stream (code C61) is an LMIA-exempt route for a multinational to place a key employee in a brand-new Canadian branch, subsidiary, or affiliate — for a maximum of one year, after which the worker transitions to the executive/manager (C62, up to seven years total) or specialized-knowledge (C63, up to five years total) category. The business plan is the document that carries the new-office case: it must evidence the foreign enterprise's financial capacity to establish and operate the venture through ramp-up, a staffing roadmap sized to support the executive, managerial, or specialized role, a premises strategy, and the qualifying parent/branch/subsidiary/affiliate relationship between the two entities. Bridge Note builds that plan to answer each criterion IRCC names; the officer assesses the evidence and decides. We never represent that a plan secures approval — the decision sits entirely with IRCC.

Frequently asked questions

What are ICT codes C61, C62, and C63?

Under the International Mobility Program's intra-company transferee category (R205(a)), IRCC uses three administrative codes. C61 is the start-up/new-office stream for transferees entering Canada to establish a new branch, subsidiary, or affiliate. C62 covers executives and senior managers (NOC TEER 0 for executives, TEER 1 for managers). C63 covers specialized knowledge workers who hold both advanced proprietary knowledge and an advanced level of expertise. The old C12 code was replaced by these three in IRCC's 2024 revision of the instructions.

Does an ICT new office application need a business plan?

Yes. IRCC's program delivery instructions require a C61 (start-up) applicant to provide a business plan and financial documentation as evidence that the foreign enterprise has the capacity and financial ability to cover the costs to establish the enterprise in Canada and to keep operating it through the initial ramp-up period. The plan must also support reasonable HR plans to hire or maintain staff, and show the applicant is entering to secure physical commercial premises. The business plan is one input among several the officer weighs.

How long is the initial ICT new office work permit valid?

Per IRCC, a C61 work permit to establish a qualifying enterprise is issued for a maximum of one year, and no extensions are available under that code. IRCC expects that within that one year the enterprise will become actively engaged in providing a good or service in Canada, after which the worker would apply under the executive/manager code (C62) or specialized knowledge code (C63) for any further work. Extensions of C61 itself are granted only in rare, documented circumstances beyond the applicant's control.

What qualifying relationship must exist between the foreign and Canadian entity?

The Canadian and foreign enterprises must be legal entities with a parent, branch, subsidiary, or affiliate relationship, established through ownership and control. The foreign enterprise must be part of a multinational corporation — a company with revenue-generating operations in at least one country beyond its home country. For a new office, the foreign side must already qualify as an MNC; an entity that exists in name only, with no employees, does not meet IRCC's "doing business" test.

Can the owner of a foreign company use the ICT new office stream?

Only in limited circumstances. IRCC states that foreign nationals (or their immediate family members) who own a controlling interest in the foreign enterprise and are seeking entry to start a new business are not eligible as an ICT unless they can demonstrate that their enterprise meets the definition of a multinational corporation. A sole founder with a single foreign company and no qualifying multinational footprint generally will not fit C61. The owner-operator route under the International Mobility Program is a separate stream with its own rules.

What financial evidence does an ICT new office plan need to show?

IRCC weighs the investment commitment, the financial ability to establish and support the new operation, and the continuing viability of the foreign operation. In practice the plan and supporting documents should evidence start-up costs (premises, equipment, hiring), projected operating costs through ramp-up, and the source of funds on the foreign enterprise's balance sheet. IRCC does not publish a fixed minimum investment figure for ICT — the standard is demonstrated capacity to fund the venture, not a set dollar threshold.

Is a leased office required before applying for an ICT new office permit?

Not necessarily at the application stage. IRCC says the C61 applicant is entering Canada to secure physical commercial premises, and the enterprise may initially use its counsel's address until a premise in Canada can be purchased or leased. By the time a C61 holder seeks to transition to C62 or C63, however, IRCC expects evidence that physical premises have been secured. The plan should set out the premises strategy and timeline rather than leaving it unaddressed.

Sources

1. Intra-company transferees (ICT) – [R205(a) – C61, C62, C63] – Canadian interests – International Mobility Program — Immigration, Refugees and Citizenship Canada (program delivery instructions), 2024
2. Immigration and Refugee Protection Regulations, SOR/2002-227, section 205 — Department of Justice Canada
3. Immigration and Refugee Protection Regulations, SOR/2002-227, section 204 — Department of Justice Canada
4. Employer-specific work permits – General processing – International Mobility Program — Immigration, Refugees and Citizenship Canada
5. Assessing the genuineness of the offer of employment on a work permit application — Immigration, Refugees and Citizenship Canada
6. Terms and definitions related to temporary residents (doing business, parent, branch, subsidiary, affiliate) — Immigration, Refugees and Citizenship Canada
7. Job Bank — Trend analysis: Search wages (prevailing wage) — Employment and Social Development Canada