Assignment letters & secondments — economical, fixed fee

The assignment letter is a tax document. Assignment letters & secondments. The assignment letter is a tax document. Economical tax advice on assignment letters & secondments 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.

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

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  • 18,000+ clients served
  • 15+ years of cross-border experience
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The short answer

The assignment letter is a tax document. Where the host entity directs and bears the cost, the arrangement looks like host employment for treaty purposes.

Do you need this?

  • A local authority has queried why no payroll is registered
  • Social security is being paid to two systems for the same person
  • A relocation package was agreed without modelling it after tax
  • An employer-of-record provider handles payroll and nobody has tested the presence risk
  • A home-country payroll is still running for someone who has moved

Most people who need help with assignment letters & secondments tick at least two of those. If you tick none, we would rather tell you that on a call than take an engagement you do not need.

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

Fixed-fee pricing for Assignment letters & secondments

An assignment letter is priced on what has to be settled before it can be drafted: who employs, who directs the work and who bears the cost, and whether this is a single secondment or a policy covering a population of assignees. Reviewing an agreement already signed sits differently from writing one from the start.

Cross-border payroll setup — fixed-fee price
From $999

in US dollars, fixed and quoted before work starts

Registrations, source deductions and reporting in the country of work, plus the social security certificate and the day-count discipline that supports the position.
See the full fee page
PE / structure opinion — fixed-fee price
From $999

in US dollars, fixed and quoted before work starts

A written opinion on whether the activity creates a taxable presence, what would be attributable to it if it did, and what could be changed to alter the answer.
See the full fee page
Payroll & mobility setup
From $999

in US dollars, fixed and quoted before work starts

Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.
See the fee schedule
Corporate cross-border filing
From $999

in US dollars, fixed and quoted before work starts

Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.
See the fee schedule
Individual tax filing
From $349

in US dollars, fixed and quoted before work starts

One engagement for a personal return that touches more than one country: the income, the assets held abroad and the relief claimed against them.
See the fee schedule
Transfer pricing documentation
From $2,500

in US dollars, fixed and quoted before work starts

Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.
See the fee schedule
Non-resident & departure filings
From $349

in US dollars, fixed and quoted before work starts

For anyone taxed by a country they do not live in — rent, pensions and investment income reaching across a border after the move.
See the fee schedule
Foreign asset & information reporting
From $349

in US dollars, fixed and quoted before work starts

Accounts, property and company interests held outside the country of residence, reported on the schedules that carry penalties whether or not tax is owed.
See the fee schedule

All published fees on one page — every engagement, one list, no ranges hiding surprises.

The rule behind the paperwork

The assignment letter is a tax document. Who employs, who directs, who bears the cost and who bears the risk decide the payroll, the treaty position and the permanent-establishment risk.

Where the host entity directs and bears the cost, the arrangement looks like host employment for treaty purposes. Secondment agreements that leave the economic employer ambiguous are the ones that produce assessments on both sides.

The consequence is that assignment letters & secondments is rarely won or lost on the return itself. It is decided by whether the right document existed at the right moment, and by whether the two countries were dealt with in the order that makes the relief usable rather than merely claimable.

Every statutory figure that reaches your file is checked against the authority that issues it, for the year in question, before anything is filed. Where we cannot verify a number for your year, the advice explains the mechanism instead and says so plainly, because an unverified threshold is a liability rather than a shortcut. See also related-party goods purchases — transfer pricing and tax for offshore vessel crew.

What we actually file

  • Day-count records assembled from travel data
  • Year-end reconciliations between the two payrolls
  • Host and home payroll registrations and returns
  • Waivers and certifications that remove withholding where a treaty applies
  • Certificates of coverage for social security

Worked through with figures

Worked through with figures, the mechanism looks like this.

Splitting one salary between two countries

A salary of C$228,000 for a year with 245 working days, 96 of them performed in the other country. Employment income is generally sourced to where the work was physically done.

Splitting one salary between two countries
ItemAmount
Annual salaryC$228,000
Working days in the year245
Days worked in the other country96
Days worked at home149
Income sourced to the other countryC$89,339
Income sourced at homeC$138,661

C$89,339 is sourced abroad on this split, which is the figure the host country taxes and the figure the home credit is computed on. Reproduce this from a travel record, not from memory — it is the first thing an auditor asks for. We run this on your actual numbers before advising anything, because the conclusion can invert with a modest change in inputs.

These amounts illustrate the mechanism only. The rates and thresholds are assumptions of the example, not your numbers: each is checked against the issuing authority for your specific tax year before any return is filed.

From first call to filed

  1. 1A short call to work out what actually applies to you and what does not
  2. 2A written quote against a defined scope, with nothing billed by the hour
  3. 3We prepare, a named reviewer checks it, and you see it before it goes
  4. 4You approve, we file, and only then do you pay

What it costs

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.

  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.
  • Every statutory figure in your file is verified for your own year at source.
  • Documents move through an access-controlled portal rather than email.

Your next step

We would rather scope it properly than quote it quickly. Start with the dates. Arrival, departure, transaction, notice — whichever applies. Once those are fixed, the filing set and the fee follow quickly, and you will know both before committing to anything.

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

Payroll mobility tax, in practice

Readers arrive here searching for payroll mobility tax, and assignment letters & secondments is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.

The assignment letter is a tax document.

From first contact to filed return

  1. Hand over the paperwork in any state

    Sorting it is our job. Send what exists and we identify what is missing from it.

  2. Priced before a single form is opened

    The fee comes from the documents, agreed in writing, and stays where it was agreed.

  3. One position across every return

    The same facts, filed consistently on each side, so nothing contradicts anything else.

  4. Filed after you have read it

    The completed work reaches you before it reaches an authority.

How Assignment letters & secondments is handled here

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

The vocabulary this page leans on

Apportionment
The division of a multi-state or multi-province tax base between jurisdictions by formula, usually on sales, payroll and property.
NR4
The Canadian slip reporting amounts paid to non-residents and the tax withheld. Its codes decide whether the recipient can claim a treaty rate or a credit.
Safe harbour
A prescribed margin or method that a taxpayer may adopt for certainty, generally set above what a study would support. Certainty bought at a premium.
Non-resident alien
A US tax classification for someone who is neither a citizen nor a resident under the green-card or presence tests. Non-resident aliens are taxed on US-source income and on income connected with a US business.
Assignment letters & secondments: How we read this one

Where the host entity directs and bears the cost, the arrangement looks like host employment for treaty purposes.

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 Assignment letters & secondments

The second driver is how far the consequences have to be followed through. A secondment that needs the host payroll registered, social security coverage confirmed and the permanent-establishment exposure written up carries more work than a letter tidied so the economic employer is no longer ambiguous. Fees are agreed in writing first.

Corporate cross-border filing
$999in US dollars, fixed before work starts

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

See this fee page
Individual tax filing
$349in US dollars, fixed before work starts

Covers: A personal filing built from your own documents — employment, investment and rental income across borders, with the treaty position set out.

See this fee page

Why choose Legal Quotient for Assignment letters & secondments

4 global offices

Meet us in person in India, the USA, Canada and the UAE, or send everything through the secure portal — the same process either way.

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

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.

Late and missed years are ordinary work

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.

The team reviewing a file together at a desk
Two of the firm’s advisers at the glass desk in the Delhi office

From first document to filed return

  • Step 1: Tell us the dates and we will tell you the position – Arrival, departure, the years in between — the residence question turns on those before anything else.
  • Step 2: Fixed fee, defined scope, in writing – Both agreed before work starts, so the engagement cannot grow into a larger bill.
  • Step 3: Prepared together, not passed between firms – You are not the go-between for two sets of advisers working from two sets of assumptions.
  • Step 4: Reviewed, approved, filed – A named practitioner checks it, you approve it, and then it goes.

Quoted up front, in writing.

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

Where to go next

Every link below is a full page of its own — the same depth as this one, for its own subject.

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Form 1040-ES — estimated tax from abroad Its own page: form 1040-es estimated tax abroad — mechanism, deadlines and published fees.
Notice of objection (Canada) Everything on notice of objection Canada, at the same depth as this page.
Form T1248 — residency information schedule T1248 residency information schedule — the guide, the FAQ and the fixed fee.
Form RC199 — voluntary disclosure application The full guide to rc199 voluntary disclosure application, with the fee fixed before any work starts.
s.247 contemporaneous documentation (Canada) Its own page: s.247 contemporaneous documentation (Canada) — mechanism, deadlines and published fees.
Power of attorney for Indian tax matters Everything on power of attorney for Indian tax matters, at the same depth as this page.
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The corridors we work every week

China tax for expats — country guide China tax for expats — the guide, the FAQ and the fixed fee.
Slovenia tax for expats — country guide The full guide to slovenia tax for expats, with the fee fixed before any work starts.
South Korea tax for expats — country guide Its own page: South Korea tax for expats — mechanism, deadlines and published fees.
Japan tax for expats — country guide Everything on Japan tax for expats, at the same depth as this page.
Qatar tax for expats — country guide Qatar tax for expats — the guide, the FAQ and the fixed fee.
Spain tax for expats — country guide The full guide to Spain tax for expats, with the fee fixed before any work starts.
Finland tax for expats — country guide Its own page: Finland tax for expats — mechanism, deadlines and published fees.
Panama tax for expats — country guide Everything on panama tax for expats, at the same depth as this page.
Chile tax for expats — country guide Chile tax for expats — the guide, the FAQ and the fixed fee.

The people on your file

Named practitioners, each with the countries and the part of a cross-border file they carry, across India, the USA, Canada and the UAE. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE, Legal Quotient Consultants
Director, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE

CA (India), CA (Malaysia)

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

Abhinav Gupta, India international tax, cross-border tax and transfer pricing, Legal Quotient Consultants
Director, India international tax, cross-border tax and transfer pricing

CA (India)

Indian cross-border files: residents with income abroad, non-residents with income in India, and the treaty relief that ties the Indian return to the one filed in the other country.

Raghav Gupta, UAE and India international tax, cross-border tax and transfer pricing, Legal Quotient Consultants
Director, UAE and India international tax, cross-border tax and transfer pricing

FCA (India)

Files that run between the UAE and India: residence, the treaty position, and the benchmarking and documentation behind intercompany pricing.

Meet the whole team

Cross-border tax case studies

Case study 1

Secondment drafted with tax terms reviewed before the assignment began

An employer sending a staff member on secondment needed the assignment letter's tax-related terms reviewed before the assignment began, since the letter itself functions as a tax document once the assignment is under way. We reviewed the draft letter and corrected the terms before it was signed by either party.

Case study 2

Existing secondment's letter revised after the assignment's terms changed

An employer whose secondment terms changed partway through an assignment needed the original letter revised to reflect the new arrangement, since the outdated letter no longer matched what the employee was actually doing. We reviewed the changed terms and revised the letter to reflect the assignment as it actually stood.

Case study 3

Group's secondment letter template standardized across multiple assignees

A group sending several employees on assignment at different times needed a standard secondment letter template built so each assignment's tax terms were addressed consistently rather than drafted individually each time. We built a template covering the group's common assignment patterns and adapted it for the specific employees using it.

Case study 4

An Assignment Priced on an Equalisation Promise

A policy that leaves the assignee no better or worse off has to be computed, not just stated, and the hypothetical deduction runs alongside the real one. The engagement builds both and reconciles them at year end.

Read how this one runs
Case study 5

Options Granted in India and Exercised Elsewhere

Where the grant, the vesting and the exercise happen in different countries, each may claim part of the same gain. Apportioning it across the period worked is what prevents the whole amount being taxed twice.

Read how this one runs
Case study 6

Social Security Paid Twice Until a Certificate Arrived

Income tax relief does not reach a social security charge; only an agreement does, and only against a certificate from the system actually being paid into. Obtaining it is the work, and it is often retrospective.

Read how this one runs
Case study 7

A Student or Researcher Covered by a Treaty Article

Several treaties carry a dedicated article for students, trainees and visiting researchers that displaces the ordinary employment rules. Whether it applies turns on the purpose of the stay and the source of the funds, both of which are evidenced rather than asserted.

Read how this one runs
Case study 8

Paid for Work Done in Canada While Living Elsewhere

Employment carried out in Canada is taxable here even where the employer and the bank account are not. The engagement establishes how many of the days were worked in Canada, applies the treaty employment article, and deals with the withholding the payer has already taken.

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
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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
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Importers, Exporters & Manufacturers
  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
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Athletes, Artists & Entertainers
  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
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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

Assignment letters & secondments — questions we are asked

Assignment letters & secondments — can I handle this 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: where the host entity directs and bears the cost, the arrangement looks like host employment for treaty purposes.

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.

What should an assignment letter cover for a cross-border secondment?

An assignment letter should set out who employs the individual during the secondment, which entity bears the cost of their compensation, how long the arrangement is expected to run, and what happens to benefits and any home-country obligations during that period. Vague or incomplete letters are a common source of disputes later over which entity owes payroll tax where. We review the letter against both countries' rules before it is signed, not after the assignment begins.

Who is treated as the legal employer during an international secondment?

Depending on how the arrangement is structured, either the home entity, the host entity, or both can be treated as an employer for different purposes, such as payroll withholding in one country and social security contributions in another. Tax authorities do not always accept the label the parties chose in the paperwork if the actual working relationship points the other way. We test the practical reporting lines against the written arrangement before relying on either.

Why does the assignment letter matter for payroll tax purposes?

The terms of the assignment letter, particularly who pays the employee, who directs their work, and how costs are recharged between entities, feed directly into which country's payroll withholding and social security rules apply and to which entity. A letter that does not match the actual working arrangement can leave both entities exposed if either country's authority reviews the arrangement. We align the letter's terms with the operational reality before the secondment starts.

What is a totalization agreement and how do I use one?

A social security agreement that stops you contributing to two systems for the same work, and lets periods in both count towards benefit eligibility in either. Which system you stay in depends on the agreement's rules for your situation — a seconded employee usually remains in the home system for a set period, a locally hired one usually joins the host system. You evidence it with a certificate of coverage obtained before or shortly after the assignment starts. See certificates of coverage.

Does hiring one remote employee in another country create a tax presence?

It can, on two separate fronts, and the second applies even when the first does not. A permanent establishment may arise if the employee has a fixed place of business there or concludes contracts for you. Independently of that, employing someone locally generally brings payroll registration, wage withholding and social security contributions in their country from the first payroll — obligations that do not wait for a permanent establishment finding. Contractor paperwork does not by itself avoid either. See remote work and tax exposure.

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

Get assignment letters & secondments handled for a fixed fee

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

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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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