Economical Digital services & the marketplace rules

Digital supply rules moved the obligation to the seller or the platform rather than the buyer, which means a foreign business can owe Canadian tax on a subscription sold from another continent. Economical digital services & the marketplace rules with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

Your own file sets the fee. Send it over, and a written quote arrives before anything is prepared.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • 15+ years of cross-border experience
  • Fixed fee agreed before work starts
The short answer

Digital supply rules moved the obligation to the seller or the platform rather than the buyer, which means a foreign business can owe Canadian tax on a subscription sold from another continent. The rules distinguish supplies to registered businesses from supplies to consumers, and they assign responsibility between the vendor and the platform operator.

Who this applies to

  • You have paid foreign tax on business costs and never reclaimed it
  • A registration was taken on a route that blocks input recovery
  • The same price is being reported to a customs authority and a tax authority
  • You sell goods or digital services into another country
  • Stock is held in a country where you have no entity

Any two of those together and digital services & the marketplace rules is almost certainly your situation. If nothing on the list applies, the helpline call still costs nothing and we will redirect you.

Two of the firm’s advisers and the team in the open-plan office

Transparent, fixed pricing for digital services & the marketplace rules

Digital services and the marketplace rules are priced by the number of countries you sell into and by how your sales reach the customer. Direct subscriptions, where you already hold the buyer status and location data, are shorter work than a mix of own-site and platform sales that has to be separated supply by supply.

GST/HST non-resident registration — fixed-fee price

From $400

fixed, quoted before work starts

The registration on the route that fits the business, plus the place-of-supply mapping that decides the rate on each sale and the input recovery position.
See the full fee page

Corporate cross-border filing

From $999

fixed, quoted before work starts

The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Payroll set up for a workforce split across countries, including the relief that stops the same salary being withheld on twice.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

Returns for the year you leave, the year you arrive, and the years you earn rental or pension income from a country you no longer live in.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

Returns for people whose tax position did not stay in one country, including the years residence itself is in question.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

The transfer pricing file a group needs when goods, services or finance move between its own companies across a border.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Voluntary disclosure handled as one piece of work, from the review of what is outstanding to the returns that close it.
See the fee schedule

All published fees on one page — all of it on a single page, so the number you compare is the number you pay.

The mechanism, in plain terms

Digital supply rules moved the obligation to the seller or the platform rather than the buyer, which means a foreign business can owe Canadian tax on a subscription sold from another continent.

The rules distinguish supplies to registered businesses from supplies to consumers, and they assign responsibility between the vendor and the platform operator. Determining the customer's status and location is the compliance work.

The practical reading of that is simple enough. Establish the position first, in writing; assemble the evidence that supports it; then prepare the filings in the order that lets the relief actually land. Doing those three in the other order is how the cost of digital services & the marketplace rules multiplies.

Because a wrong number is worse than no number, every rate and threshold in your file is confirmed for your year at source. Where that confirmation is not available in time, the advice states how the rule works and what would need checking, rather than filling the gap with an estimate. See also tp for small and mid-size groups and local resident director services in Canada.

What we actually file

  • Periodic indirect-tax returns and reconciliations
  • Import, marketplace and reverse-charge documentation
  • Recovery claims for input tax and foreign value-added tax
  • Threshold monitoring by destination, tested against each local rule
  • A registration-route analysis where input recovery is at stake

The arithmetic, worked through

Here is the rule doing its work on an actual set of amounts.

Where a registration obligation actually starts

An online seller with C$1,526,000 of sales across 4 markets. Assume the largest market takes C$534,100 of that and assume a registration test of C$66,000 in that market.

Where a registration obligation actually starts
ItemAmount
Total salesC$1,526,000
Markets sold into4
Sales in the largest marketC$534,100
Assumed registration test thereC$66,000
Registration required in that market?Yes

One market crosses its own test, so registration and collection start there on the trigger date — and the other 3 markets are tested separately, on their own rules. Registering in one does nothing for the next. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.

How we handle it

  1. 1We start with the chronology: dates, countries, and what has already been filed
  2. 2You get the scope and the fee in writing before we touch anything
  3. 3The work is prepared and reviewed by a named person, not a queue
  4. 4Nothing is filed until you have read it

Fees for this work

You get a number before you commit, not an estimate that drifts. The scope is written down, the fee is fixed against it, and if the scope changes we re-quote rather than invoice the difference. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Every statutory figure in your file is verified for your own year at source.
  • We will tell you when you do not need us, and that call is free.
  • Documents move through an access-controlled portal rather than email.

Where to go from here

If a letter prompted this, bring the letter — it usually contains the answer to half the questions. Bring the last two years of returns from each country involved, the slips or certificates for the income in question, and the dates — arrival, departure, or the transaction date. That is enough for us to tell you what has to be filed and what it will cost.

Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Where business tax advisory comes into this file

Read this page for business tax advisory. It works through digital services & the marketplace rules from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.

Digital supply rules moved the obligation to the seller or the platform rather than the buyer, which means a foreign business can owe Canadian tax on a subscription sold from another continent.

The four phases of the work

  1. Send the documents as they are

    No tidying required — forward what you have and we tell you what is missing.

  2. Get a fixed quote in writing

    Priced from your actual documents before any work begins, not estimated after.

  3. Both countries prepared together

    One team builds the filings against each other so the relief lands exactly once.

  4. Review, then file

    You approve the finished work before we file it.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Key terms behind this page, defined

Simplified registration
A sales-tax registration route for non-resident digital suppliers that is easier to operate and gives no input tax recovery — the wrong trade for a business with local costs.
Foreign grantor trust
A non-US trust with a US settlor treated as grantor, bringing US information reporting and taxation of the trust's income to that settlor.
Excess distribution
A distribution from a foreign pooled investment above a permitted amount, thrown back across the holding period with an interest charge under the default regime.
Reverse hybrid
An entity treated as a company by the country of establishment and as transparent by the investor's country, the mirror image of the classic hybrid.
digital services & the marketplace rules: Our analysis

The rules distinguish supplies to registered businesses from supplies to consumers, and they assign responsibility between the vendor and the platform operator.

None of what follows shifts the terms. Scope and fee are settled in writing before anything is prepared, the result carries a named reviewer, and nothing is filed unseen.

The published fees closest to digital services & the marketplace rules

Back periods are the other half. Registering from today is a defined task; establishing when a threshold was first crossed, and what is owed on supplies already made, means rebuilding the sales history by destination and customer type. Call +1 (416) 619-0068 and say which countries are involved.

Payroll & mobility setup

$999fixed, before work starts

Covers: Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.

See this fee page

Non-resident & departure filings

$349fixed, before work starts

Covers: Arrival and departure years priced as one engagement, with the part-year residence position and the assets deemed disposed of on exit.

See this fee page

The difference a dedicated cross-border team makes

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

The quote comes from your documents

Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.

18,000+ clients served

Individuals, expats and corporations across India, the USA, Canada and the UAE have filed with us — 15+ years of cross-border work.

Both sides prepared together

Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.

The team at work in the open-plan office

Digital services & the marketplace rules — the four phases

Step 1

Initial call

We establish what happened and when, because every position here is anchored to a date

Step 2

Scope and fee

A written scope and a fixed price, so you know the cost before committing

Step 3

Preparation and review

The filings are prepared, cross-checked against each other, and reviewed by name

Step 4

Filing and payment

You see the result, approve it, and we file it

The firm’s founder at his desk in the Delhi office

From first document to filed return

  • Step 1: Hand over the paperwork in any state – Sorting it is our job. Send what exists and we identify what is missing from it.
  • Step 2: Priced before a single form is opened – The fee comes from the documents, agreed in writing, and stays where it was agreed.
  • Step 3: One position across every return – The same facts, filed consistently on each side, so nothing contradicts anything else.
  • Step 4: Filed after you have read it – The completed work reaches you before it reaches an authority.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

More of the same work, from other angles

Browse sideways: the pages below answer the neighbouring questions.

Core services for this situation

Form T2091 — principal residence exemption: capital gains, foreign Principal residence exemption capital gains foreign property — the guide, the FAQ and the fixed fee.
Estate administration across borders The full guide to estate administration across borders, with the fee fixed before any work starts.
IRS streamlined foreign offshore Its own page: IRS streamlined foreign offshore — mechanism, deadlines and published fees.
Intangibles & DEMPE analysis Everything on intangibles & dempe analysis, at the same depth as this page.
Foreign seller: capital gains and the clearance certificate Foreign capital gains clearance certificate — the guide, the FAQ and the fixed fee.
Non-resident with Canadian employment income The full guide to non-resident Canadian employment income, with the fee fixed before any work starts.
Crypto and the FBAR question Its own page: crypto and the FBAR question — mechanism, deadlines and published fees.
Form 8288-C — section 1446(f) withholding Everything on form 8288-c section 1446f withholding, at the same depth as this page.
Form 49A — PAN (residents) (India) Form 49a India — the guide, the FAQ and the fixed fee.

Who we bring this work to

Technology & SaaS cross-border tax Technology & saas cross border tax — the guide, the FAQ and the fixed fee.
IT contractors — what we charge The full guide to it contractors what we charge, with the fee fixed before any work starts.
Education & ed-tech cross-border tax Its own page: education & ed-tech cross border tax — mechanism, deadlines and published fees.
Tax for architects Everything on architects tax, at the same depth as this page.
Software developers — what you owe in each country Software developers what you owe in each country — the guide, the FAQ and the fixed fee.
Tax for physicians & surgeons The full guide to physicians & surgeons tax, with the fee fixed before any work starts.
Tax for short-term rental hosts Its own page: short-term rental hosts tax — mechanism, deadlines and published fees.
Civil & structural engineers — your filing calendar Everything on civil & structural engineers your filing calendar, at the same depth as this page.
Veterinary practices cross-border tax Veterinary practices cross border tax — the guide, the FAQ and the fixed fee.

The corridors we work every week

Ecuador tax for expats — country guide Ecuador tax for expats — the guide, the FAQ and the fixed fee.
Zimbabwe tax for expats — country guide The full guide to zimbabwe tax for expats, with the fee fixed before any work starts.
Lebanon tax for expats — country guide Its own page: lebanon tax for expats — mechanism, deadlines and published fees.
Slovakia tax for expats — country guide Everything on slovakia tax for expats, at the same depth as this page.
Uganda tax for expats — country guide Uganda tax for expats — the guide, the FAQ and the fixed fee.
Moldova tax for expats — country guide The full guide to moldova tax for expats, with the fee fixed before any work starts.
Poland tax for expats — country guide Its own page: Poland tax for expats — mechanism, deadlines and published fees.
Canada–UAE tax corridor Everything on Canada UAE tax, at the same depth as this page.
Canada–Hong Kong tax corridor Canada Hong Kong tax — the guide, the FAQ and the fixed fee.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

What these engagements turn on

Case study 1

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 2

An Adjustment in One Country and No Relief in the Other

A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.

Read how this one runs
Case study 3

Expanding Abroad — Branch or Subsidiary, Decided on the Numbers

The choice sets the tax on profits, the treatment of early losses, and what it costs to take money home later. The file models all three across the first years rather than deciding on the incorporation cost alone.

Read how this one runs
Case study 4

A Margin Defended With a Benchmarking Set That Fits the Facts

A comparables set is only as good as the screening behind it, and a rejected set takes the margin with it. The study selects the tested party first, screens on function rather than on industry code, and records why each comparable survived.

Read how this one runs
Case study 5

A Taxable Presence Created Without an Office

A dependent agent habitually concluding contracts can create a permanent establishment where there is no premises at all. The review tests what the person actually does against what the treaty describes.

Read how this one runs
Case study 6

One Salesperson Abroad, and a Corporate Filing Obligation

A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.

Read how this one runs
Case study 7

An Estate That Cannot Distribute Until the Clearance Comes

An executor who distributes before the clearance certificate can be held personally liable for what is later assessed. The file prepares the final return and the estate return, and applies for the clearance in the order that lets the estate close.

Read how this one runs
Case study 8

Documentation Built to the US Standard

The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.

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

Professional Services Firms

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

  • Reg 105 / 102 waivers
  • Permanent establishment risk
  • Partner mobility planning
  • Cross-border withholding recovery
Explore Professional Services

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

Digital services & the marketplace rules — questions we are asked

Digital services & the marketplace rules — how much of this can I do myself?

Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: the rules distinguish supplies to registered businesses from supplies to consumers, and they assign responsibility between the vendor and the platform operator.

What if I have already filed and got it wrong?

That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.

How long will it take?

It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.

Which countries have a tax treaty with the United States?

Around sixty, including Canada, the United Kingdom, India, Australia and most of western Europe — but the list matters less than the terms, because each treaty caps rates and allocates income differently. Two countries with treaties can produce opposite answers on the same pension or the same royalty. What decides your position is the specific article covering your income type. See our country guides.

Which country do I pay tax to first?

Generally the source country — where the income arises — taxes first, often by withholding before you receive it. Your country of residence then taxes the same income and credits what the source country took. That order is why timing matters: a residence-country return filed before the source-country tax is settled has nothing to credit yet. Getting the sequence right is most of the work. See international tax planning.

Do I pay tax when I inherit property abroad?

The inheritance itself is often not income to you, but three other things can create tax: the estate may owe tax where the deceased or the property was situated, some countries tax the recipient directly, and the gain from the date you inherit to the date you sell is yours. Reporting obligations can also attach to holding the asset. See inheriting property abroad.

How is the fee set?

It is agreed in writing before any work begins, based on the scope we establish on the first call. If the scope changes we re-quote before continuing — there is no hourly meter running in the background.

Will you tell me what I could have done differently?

Yes, including where the window has closed. Knowing that a step was available last year is the reason next year is cheaper.

15+ years of cross-border experience

Digital services & the marketplace rules, quoted before we start

Send us the facts. You will get a scope and a fixed fee in writing, and nothing starts until you agree to both.

  • 24-hour helpline, +1 (416) 619-0068
  • Rated 5.0 out of 5 stars on Google
  • A named reviewer signs off every filing

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.

Request a Quote +1 (416) 619-0068