99 jurisdictions listed
Source: Department of Finance Canada
What this guide is, and what it deliberately leaves out
This guide answers one question per jurisdiction: which countries has this tax authority actually got an agreement with, and what status does it publish for each one. Everything in the four partner tables was read off the publishing authority's own page or document on 19 August 2026 and transcribed as printed, footnotes and awkward country names included.
What the guide deliberately does not contain is a per-treaty table of dividend, interest and royalty rates. Those caps commonly step with the size of a shareholding, protocols move them, and the multilateral instrument can change which article applies at all — so each page explains the mechanism, tells you what the reduced rate depends on and what has to be filed to claim it, and quotes no number it has not verified. A wrong rate on a page like this is worse than no page.
The treaty articles themselves — the residence tie-breaker, permanent establishment, business profits, employment income, pensions, the elimination-of-double-taxation article, limitation on benefits, the MLI and its principal purpose test, the mutual agreement procedure and certificates of residency — are covered in depth under treaty services. These four pages point at those rather than repeat them.
The four desks
North America
Two networks that share a border and almost nothing else in how they work.
68 jurisdictions listed
Source: Internal Revenue Service
Asia
A broad DTAA network where documentation, not entitlement, decides most outcomes.
96 countries listed
Source: Income Tax Department, India
Middle East
A wide agreement network with one significant gap and one recurring substance question.
142 jurisdictions listed
Source: Ministry of Finance, United Arab Emirates
How each list was sourced
- Canada — Department of Finance Canada, Department of Finance Canada — Tax treaties, page date modified 21 July 2026. Retrieved 19 August 2026.
- India — Income Tax Department, India, Income Tax Department — Handbook on Advance Rulings (PDF), Annexure-II, “List of the countries with which India has DTAA”. Retrieved 19 August 2026.
- United States — Internal Revenue Service, IRS — United States income tax treaties A to Z, page last reviewed or updated 03-Jan-2026. Retrieved 19 August 2026.
- United Arab Emirates — Ministry of Finance, United Arab Emirates, UAE Ministry of Finance — Double Taxation Agreements, partner rows from the Ministry’s published DTA table (PDF, document created May 2023). Retrieved 19 August 2026.
Each page carries a visible source line with the publisher, the URL and the date the list was retrieved. Where an authority publishes no status — India's list is a flat list of countries — the guide says so rather than inventing one. If a figure or a status has moved since 19 August 2026, the authority's own page is the one to trust, and we would rather you told us than acted on a stale row.
Files that look like this one
Case study 1
Checking treaty status before a group moved its holding company
A group intended to place a new holding company in a jurisdiction its adviser described as treaty-covered on both sides. Read off the publishing authorities' own lists, one of the two agreements had been signed and was not yet in force. The work was to establish the actual status from each source, then set out what the position would be for payments made before entry into force. The engagement produced a written status note for both relationships and a recommendation to defer the step until the position was settled.
Case study 2
A payment routed through a jurisdiction with no treaty in force
Withholding had been applied at the domestic rate on a series of payments and the payer assumed no treaty reduction was available. Checking the publishing authority's list showed an agreement in force with the recipient's country of residence; the obstacle was not the treaty but the paperwork required before payment. The work was to confirm the status, establish residence for treaty purposes, and put the documentation in place for future payments. The engagement produced a corrected process going forward and a reclaim position for payments already made.
Case study 3
Confirming which text applied after a protocol was signed
A client had read that a protocol changed the article they were relying on, and wanted to know whether it applied to a transaction already under way. The work was to establish what had been signed, whether it had entered into force, and from what date each affected article had effect, since those dates commonly differ between withholding taxes and other taxes. The engagement produced a dated note setting out which text governed the transaction and what would change for the following year.
Case study 4
Two desks consulted for one payment between group companies
The payer and the recipient sat in different regions of this guide, and each side's adviser had checked only its own authority's list. The two descriptions of the relationship did not match. The work was to read both publishing sources, reconcile the difference, which came down to one side listing a re-negotiation alongside an agreement already in force, and state the position once. The engagement produced a single reference note both advisers worked from, and a record of what each authority published on the date it was read.
Case study 5
A treaty position checked against the source rather than a summary
The position had been taken from a commercial database entry giving a country name and nothing else. The publishing authority's own page showed the same country under two headings at once, which changed the answer materially. The work was to go back to the source for every treaty the client relied on, record the status as printed, and note the retrieval date beside each. The engagement produced a working file that can be reconstructed later, which is what an auditor asks for when a treaty benefit is claimed.
Case study 6
Reading a partner list where one country appeared in two groups
A client concluded from a partner table that a new agreement had replaced the old one and that relief was therefore unavailable in the meantime. In fact the same country was listed once as in force and again as signed but not yet in force, which is a normal state of affairs while a successor agreement waits on ratification. The work was to explain the two entries and identify which text governed today. The engagement produced a note confirming that relief remained available under the existing agreement.
Case study 7
Two Passports, Two Returns, One Income
Dual citizenship does not let you choose which country taxes you. The work is establishing residence, applying the treaty article that governs each income type, and preparing both returns from one set of figures so they agree line for line.
Read how this one runs
Case study 8
An Indian Company Paying a Foreign Supplier
Payments abroad carry deduction at source and a certification filed before the money moves. Whether the treaty reduces the rate depends on what is being bought, and the classification is the decision the whole filing rests on.
Read how this one runsAll 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.
Tax Treaties & Withholding
Relief is only as good as the paperwork claiming it — we build treaty positions that survive review on both sides.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Global Investments & Reporting
Information returns carry the sharpest penalties — $25 a day whether or not any tax is owing. We keep them clean and on time.
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
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Who We Serve:
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Who We Serve:
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Who We Serve:
Cross-Border Real Estate
Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.
Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Who We Serve:
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Who We Serve:
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Who We Serve:
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Who We Serve:
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
Who We Serve:
