Authorised representative — meaning in cross-border tax

Authorised representative explained: its meaning in cross-border practice, and why it matters to your filing.

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Definition

A person authorised with a tax authority to see assessments and slips and to act for the taxpayer — usually where the discrepancies are found.

What turns on it

Process terms describe how the engagement runs rather than how the tax is computed — which matters, because most of what goes wrong in a cross-border file is a sequencing or documentation failure rather than a technical one.

Two of the firm’s advisers at a desk in the Delhi office

Where the definitions diverge

Where the two systems do use the same concept, they rarely draw its edges in the same place. The middle of the definition is uncontroversial and the edge is where cross-border files live, so the edge is what gets checked rather than the definition.

The filings it touches

How to use this

Recognising Authorised representative in your own paperwork is the useful skill. Working out which side of it you fall on is a short call. We will tell you if you do not need us. That happens more often than you would expect.

These entries stop at the point where the answer starts depending on your own facts. Past that line a page cannot be right for everyone, and being confidently wrong in general is worse than being useful in outline.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

International tax accountant, in practice

The subject here is authorised representative, which is what people mean when they search for international tax accountant. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.

Cross-border tax case studies

Case study 1

Reading the authority's own record before filing a catch-up return

A client returning to filing after some years abroad believed he knew what had been reported in his name. Authorisation was obtained first, and the authority's record showed slips from a payer he had stopped thinking about and an assessment he had never seen. The returns were then prepared against what the authority actually held rather than against memory, and the difference was explained in the filing instead of being left for a reassessment to raise. The engagement produced the filed years and a documented reconciliation between the client's records and the authority's.

Case study 2

Cancelling a predecessor's access that had outlived the relationship

A new client could not understand why she received so little correspondence. The list of authorisations on her account named an adviser she had last instructed years earlier, still holding access and still set to receive copies of notices. The old authorisation was cancelled, the current one put in place, and the missing correspondence requested from the authority so the file could be brought up to date. The engagement produced a clean list of who may read the account, and copies of the notices that had been going elsewhere.

Case study 3

Finding a payroll account that nobody had access to

A company's adviser was authorised on the corporate account and had been for some time. A notice about employee remittances arrived at the registered address and nobody could see the account behind it. Authorisation was extended account by account, which meant listing every account the company actually held with that authority rather than assuming one covered the rest. The engagement produced authorisation across each account, and a short register of the company's accounts and who is authorised on each, kept with the file for the next change of staff.

Case study 4

Getting a non-resident authorised where identity evidence did not match

A client living abroad needed her adviser authorised so that a notice could be answered, and her address and identity documents had all been issued in the country she now lives in. The first attempts were rejected by the authority's verification procedure. The work consisted of assembling documents the authority would accept and pursuing the authorisation through its process while the date on the notice was tracked separately. The engagement produced the authorisation and a reply filed against the notice, plus a note of which evidence the authority accepted, for use next time.

Case study 5

Authorisation in both countries before a treaty position was taken

A client intended to rely on a position that required consistency between what each country's authority held. Before anything was filed, authorisation was obtained with both of them, separately, each on its own form and its own timetable. Reading the two records together showed that one authority's file recorded income for a period the other treated as falling in the following year. That was resolved in the filings rather than discovered afterwards by one of them. The engagement produced authorisations on both sides and a position documented against both authorities' own records.

Case study 6

Uncovering an assessment the taxpayer had never been shown

A client asked for help with a current return. Representative access, arranged as the first step, showed an earlier assessment raised at an address he had left, with a balance and interest accruing quietly against it. Nothing in his own papers referred to it. The work consisted of obtaining the assessment and the correspondence behind it, establishing what it had been based on, and answering it in its own right before the current return was filed. The engagement produced a documented objection and a current return prepared in the knowledge of what stood behind it.

Case study 7

Paying a Dividend Up to a Foreign Parent

The withholding rate depends on the treaty, on the size of the holding, and on whether the parent is the beneficial owner rather than a conduit. Establishing all three before the payment is what secures the lower rate at source.

Read how this one runs
Case study 8

Which Country Taxes the Salary

The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.

Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Authorised representative — the questions that follow

How do I let my accountant see my tax account?

By authorising them with the tax authority itself, in whatever form that authority requires, and separately for each authority involved. The authorisation is given by you to the authority, not to the adviser, which is why signing an engagement letter does not create it. Once it is in place the adviser can see what the authority holds: assessments, notices, slips filed by third parties, instalment and balance records. That view is the reason the authorisation is worth doing early. Most discrepancies in a cross-border file are found by comparing what the authority already holds against what the taxpayer believes was reported.

Does authorising a new accountant remove my old one?

Not automatically, and it is worth checking. Authorisations sit on your account until they are cancelled or expire, so a predecessor can still hold access, and in some cases still be receiving copies of notices, long after the working relationship ended. Two consequences follow. Correspondence you never see may be going somewhere you no longer look, and a person you have not spoken to for years may still be able to read your record. When authorisation is set up for a new adviser, the sensible step is to read the list of who else is on the account and cancel what should no longer be there.

Can my accountant get slips I never received?

Often, yes, and that is one of the more useful things representative access does. Payers file copies of the slips they issue with the authority, so the authority's record can contain income entries the taxpayer never saw — a slip posted to an old address, one issued by a payer whose name he does not recognise, or one from an account he had forgotten. Reading that record before filing turns a possible reassessment into a question answered in advance. It is not a complete picture: income with no reporting slip behind it, which on cross-border files is a great deal of income, does not appear there at all.

Do I need to authorise my accountant in both countries?

If filings are being handled in both, yes, separately. An authorisation is specific to the authority it is given to, and nothing about being authorised with one country's authority carries across a border. The forms differ, the identity evidence differs, and the time each takes to come into effect differs, which is why they are worth starting before they are needed. Where one country's return depends on the other's assessment, access to both records is what lets you confirm that the figure being relied on is the one the other authority actually assessed, rather than the one on a draft return.

Can someone living abroad be authorised on a tax account?

Generally yes, though the practical obstacle is identity evidence rather than the authorisation itself. An authority verifying who is granting access has procedures built around documents and addresses it recognises, and a taxpayer whose address and identity papers were issued elsewhere can take several attempts to get through them. The work lies in assembling evidence the authority will accept, and in expecting the process to take time. It is a common reason a file stalls before any tax question is reached, and a reason to begin the authorisation at the start of an engagement rather than when a notice needs answering.

Does representative access cover all of my tax accounts?

Not necessarily. A taxpayer can hold more than one kind of account with the same authority — a personal income tax account, a business account, payroll, sales tax — and an authorisation may cover one and not the others. A company discovering that its adviser can see the corporate account but not the payroll one usually discovers it when a payroll notice needs answering. When authorisation is arranged, list the accounts that exist, check each one is covered, and treat any account nobody has access to as a place where correspondence can accumulate unseen.

How many days can I spend in a country before I become tax resident?

It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.

How would a foreign tax authority know I am resident there?

Mostly from information you or your bank already provided. Account-opening forms ask you to self-certify tax residence, and that certification is reported between authorities under the Common Reporting Standard or, for US accounts, under the FATCA framework. Beyond that: employer and payroll filings, property registries, immigration records and the tax filings of anyone who paid you. The realistic planning assumption is that the data arrives. See FATCA and information reporting.

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Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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