The India treaties read article by article, and the three documents a claim actually needs.
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24-hour helpline: +1 (416) 619-00688 pages in this section. The India treaties read article by article, and the three documents a claim actually needs.
Every page in this section is written to the same standard: it opens with the block that exists nowhere else on the site — a threshold, a treaty article, a rule that applies to one group and not the one beside it — and it carries one worked example, worked through in full rather than a set of generalities.
Where a page needs a statutory threshold, a rate or a day-count, that figure is verified against the issuing authority before it ships. Where it cannot be verified for the year in question, the page states the mechanism and quotes no number, because a wrong threshold on a page like this is worse than no page at all. Every statutory page also carries the name of the person who reviewed it and the date they did.
Fees are fixed and agreed in writing before any work begins, and you review the finished work before it is filed. Documents move through a secure portal and you can meet us at any of our offices, so where you are makes no difference to how it works.
Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.
8 pages. The India treaties read article by article, and the three documents a claim actually needs. Each one opens with the part that applies to that situation and nowhere else — a threshold, a treaty article, a filing that one group owes and the group beside it does not — and works one example through in full.
The fee is fixed and agreed in writing before any work begins, priced from the documents you send rather than estimated afterwards, and it does not move once accepted. You see the finished work and approve it before anything is filed.
A named adviser reviews every return and every information filing before it goes out, and the statutory pages on this site carry the name of the person who reviewed them and the date they did it. You approve the finished work yourself as the last step.
Send what you have — a return, a notice, a set of statements, in whatever state it is in — through the secure portal after the first call, and you get a written fixed fee back. Or call the 24-hour helpline on +1 (416) 619-0068 and we will tell you what is needed.
Usually not by itself — India generally also asks for a supplementary self-declaration form alongside the residency certificate before a reduced treaty rate is applied, so the certificate alone is typically the first of two documents rather than the whole claim.
They cover the corridors our clients most often use; a pairing not listed here is still worth checking against the official treaty text directly, since India's treaty network is large and not every corridor gets equal search volume.
An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.
International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.
Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.
The practitioner who prepared and reviewed your file is the one who answers the question about it.
Quoted up front, in writing.
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Every link below is a full page of its own — the same depth as this one, for its own subject.
An engineering firm was being paid for design work by an Indian customer who treated every invoice as a royalty and deducted accordingly. The two categories sit in different articles and carry different consequences, and the distinction turned on whether anything was being licensed at all or whether the firm was simply doing work to order. We read the contract, the deliverables and the correspondence around them, and set the characterisation out in writing against the wording of the article relied on. The engagement produced a documented position, revised invoicing language, and a claim filed for the periods already deducted on the wrong basis.
A retired couple spent part of each year in India and part in Canada, and had been filing as residents of both without ever testing which they were. We worked the treaty tests in order, gathering the evidence each one needs: property available to them, where their banking, medical care and family ties sat, and a reconstructed calendar of presence across several years. The engagement produced a written residence conclusion supported by a document file, amended returns for the years filed on the wrong basis, and a note of what to keep each year to hold the position.
A shareholder received a dividend from an Indian company on which tax had been deducted at the domestic rate, because the paying company had no residence certificate on file when the payment was approved. We obtained the certificate for the year in question, prepared the declaration of eligibility, and filed in India to claim the excess back. Alongside that we gave the company's registrar a standing pack so that later payments would be made at the treaty rate. The engagement produced a filed reclaim for the year taken in full, and correct deduction on every payment since.
An employee was seconded to an Indian group company for a project while remaining on the home payroll. The exemption for short assignments looked available on the face of it, but the Indian entity was recharging the salary cost, which changed the answer. We traced the recharge through the intercompany ledger, established the dates of presence from travel records, and set the position out under the article rather than under the payroll arrangement. The engagement produced Indian filings on the correct basis, a corrected treatment at home, and a secondment agreement rewritten so the two records agree in future.
A client sold a holding in an unlisted Indian company and faced a charge in India as well as a further computation at home on the same disposal. The two systems measure the gain differently, start from different cost figures and recognise it on different dates, so relief is not simply one tax set against the other. We prepared both computations side by side, fixed the cost base in each currency, and identified the order in which the two returns had to be filed. The engagement produced two consistent computations, relief claimed to the extent the treaty allowed, and a file explaining every figure.
The same profit had been taxed once in India and once at home, after an adjustment in one country that the other did not follow. Ordinary relief could not reach it, because neither authority accepted that the other's figure was the right one. We prepared the submission the treaty provides for, setting out the facts, the adjustment made, and why the result was inconsistent with the article relied on, and presented it to the authority in the country of residence. The engagement produced an accepted submission, a documented record of the position, and correspondence carried through to the administrations taking it up.
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 runsIncome sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.
Read how this one runsAll case studies — every published engagement in one place.
Strategy and compliance for income, assets and families spread across borders.
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.
Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.
