Resources

Global tax treaty guide

Four desks, four official sources. Open a region to reach a jurisdiction, then open the sections you need.

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

2 jurisdictions

Two networks that share a border and almost nothing else in how they work.

Global tax treaties: Canada

Canada

99 jurisdictions listed

Source: Department of Finance Canada

Global tax treaties: USA

United States

68 jurisdictions listed

Source: Internal Revenue Service

Asia

1 jurisdiction

A broad DTAA network where documentation, not entitlement, decides most outcomes.

Global tax treaties: India

India

96 countries listed

Source: Income Tax Department, India

Middle East

1 jurisdiction

A wide agreement network with one significant gap and one recurring substance question.

Global tax treaties: UAE

United Arab Emirates

142 jurisdictions listed

Source: Ministry of Finance, United Arab Emirates

How each list was sourced

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.

24-hour helpline: +1 (416) 619-0068

Need a treaty position checked, not guessed?

Send us the payment, the parties and the countries involved and we will tell you which article decides it, what has to be filed, and what it costs. The fee is agreed in writing before any work starts.

  • Fixed fees agreed before work starts
  • 18,000+ clients served over 15+ years
  • Offices in India, the USA, Canada and the UAE

Files that look like this one

Case study 1

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 2

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 runs
Case study 3

A Canadian Working in the US on a Work Visa

Immigration status and tax residence are different tests, and a visa says nothing about which country taxes the salary. The file fixes residence, applies the employment article, and sequences the two returns so the credit lands where it is usable.

Read how this one runs
Case study 4

Withheld at the Statutory Rate When a Treaty Rate Applied

Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.

Read how this one runs
Case study 5

A Residency Determination Review After Leaving the Country

Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.

Read how this one runs
Case study 6

Withholding Reduced by the Right Article

Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.

Read how this one runs
Case study 7

One Salary, Two Countries Claiming It

A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.

Read how this one runs
Case study 8

Three Account Types, Three Tax Answers

Interest on each is treated differently and the deduction at source follows the account rather than the person. Holding the wrong one for the purpose is a recurring and avoidable cost.

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

  • 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

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
Explore Real Estate

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

Our practitioners are alumni of leading accounting and tax institutions

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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