Personal services business risk — cost-effective, fixed fee

Incorporating to provide your own services can turn out to be the most expensive structure available, because rules exist specifically to deny that company the ordinary business deductions and rate. Cost-effective personal services business risk 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 the founder's cross-border experience
  • 18,000+Clients served across our offices in India, the USA, Canada and the UAE
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

Start by sending whatever paperwork exists — a written fixed quote comes back before any work begins.

24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
  • 18,000+ clients served
  • 24-hour helpline: +1 (416) 619-0068
The short answer

Incorporating to provide your own services can turn out to be the most expensive structure available, because rules exist specifically to deny that company the ordinary business deductions and rate. Where the corporation is effectively an incorporated employee, its income is taxed punitively and most expenses are disallowed.

Whether this is your situation

  • You cannot produce a day-count record for the year
  • Staff travel to work at customer sites abroad
  • 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

If more than one of those is true, this is your page. If none of them is, tell us on a call and we will point you at the right one — that happens often enough that we would rather you asked.

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

Fixed-fee pricing for Personal services business risk

A personal services business review is priced on how many contracts the corporation holds and how long the arrangement has run. Testing one current engagement against the control and integration factors is contained work; several filed years, with deductions that may be denied and a rate that may not apply, means reading everything already claimed.

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

What an employer owes when an employee works in another country: the registrations, the withholding and the reporting that follow.
See the fee schedule
Corporate cross-border filing
From $999

in US dollars, fixed and quoted before work starts

Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.
See the fee schedule
Transfer pricing documentation
From $2,500

in US dollars, fixed and quoted before work starts

Benchmarking and documentation for related-party dealings, prepared to the standard the reviewing authority applies.
See the fee schedule
Individual tax filing
From $349

in US dollars, fixed and quoted before work starts

Personal returns for individuals, expats and non-residents — foreign income, foreign property and treaty relief handled in one engagement.
See the fee schedule
Foreign asset & information reporting
From $349

in US dollars, fixed and quoted before work starts

The reporting obligations that attach to owning something abroad, worked out from your holdings rather than from the tax return alone.
See the fee schedule
Non-resident & departure filings
From $349

in US dollars, fixed and quoted before work starts

The filings that follow a move: the departure year, the arrival year, and the income that keeps arriving from the country behind you.
See the fee schedule

All published fees on one page — one page, every published fee, nothing quoted as a vague bracket.

What is really being tested

Incorporating to provide your own services can turn out to be the most expensive structure available, because rules exist specifically to deny that company the ordinary business deductions and rate.

Where the corporation is effectively an incorporated employee, its income is taxed punitively and most expenses are disallowed. The factors are the same control and integration tests used for employment status, applied to the corporate arrangement.

The rule is therefore less about arithmetic than about proof. Two people with identical numbers can end up in very different positions because one of them can evidence the date, the valuation or the residence and the other cannot.

The standard here is simple: no figure without a source for your year. Anything that cannot meet it is written as a mechanism, so you can see exactly what the rule does even where the number has to be confirmed before filing. See also limitation on benefits — the treaty test and tax for nurses working abroad.

What we actually file

  • Waivers and certifications that remove withholding where a treaty applies
  • Certificates of coverage for social security
  • Equity apportionment computations and the reporting on both sides
  • Shadow payroll and the equalisation entries that reconcile it
  • Assignment documentation that settles who the employer actually is

What this looks like with numbers

It is easier to see with numbers attached.

Splitting one salary between two countries

A salary of C$166,000 for a year with 233 working days, 89 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$166,000
Working days in the year233
Days worked in the other country89
Days worked at home144
Income sourced to the other countryC$63,408
Income sourced at homeC$102,592

C$63,408 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. The interesting question is where your own figures fall relative to that, which is a computation rather than an opinion.

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.

What working with us looks like

  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

The fixed fee

The fee is fixed and agreed in writing before work begins, based on the scope established on the first call. Nothing is billed by the hour, and the number does not move once it is agreed. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • Documents move through an access-controlled portal rather than email.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.

How to get this moving

We will tell you if you do not need us. That happens more often than you would expect. One call to our 24-hour helpline is usually enough to tell you whether this is a filing or a project, and what each would cost. The call is free, and we will say so if the answer is that you do not need us.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. General guidance only. Your own facts decide the answer, so bring them to a call before relying on this.

Where payroll mobility tax comes into this file

The subject here is personal services business risk, which is what people mean when they search for payroll mobility tax. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.

Incorporating to provide your own services can turn out to be the most expensive structure available, because rules exist specifically to deny that company the ordinary business deductions and rate.

How the engagement runs, phase by phase

  1. Upload the file as it stands

    A secure link arrives after the first call. Incomplete is fine; that is what the review is for.

  2. The number is settled up front

    Priced from your own documents and confirmed in writing before any preparation begins.

  3. Both returns on one desk

    One engagement covers every country the file touches, reconciled line against line.

  4. Your approval, then the filing

    The return is yours to check first. We file once you say so.

What you are actually buying with Personal services business risk

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

Published fee
A fee listed on this site for a defined scope, so the number is known before the first call. Legal Quotient Consultants publishes every fee it charges and confirms the one for your engagement in writing before any work starts.
TNMM
The transactional net margin method, testing an operating margin rather than a gross one — which is why it survives accounting differences that defeat gross-margin methods.
Clubbing of income
The Indian attribution of income back to a transferor where assets were transferred to a spouse or certain relatives without adequate consideration.
FATCA
The US regime requiring reporting of foreign financial assets by taxpayers and of US accounts by foreign institutions, backed by withholding.
Personal services business risk: How we read this one

Where the corporation is effectively an incorporated employee, its income is taxed punitively and most expenses are disallowed.

However the file develops, three things stay fixed: a written scope and fee before work begins, a named practitioner reviewing the result, and your approval before anything is filed.

Personal services business risk — what the published fees look like

Whether the company has other clients, staff of its own and its own equipment decides how much evidence has to be gathered, and a file the revenue authority has already queried is wider than one looked at before the contract is signed. The fee is agreed in writing before work starts.

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

Covers: Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.

See this fee page
Transfer pricing documentation
$2,500in US dollars, fixed before work starts

Covers: Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.

See this fee page

The difference a dedicated cross-border team makes

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 order of filing is planned, not improvised

Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.

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.

One team, not two firms billing separately

You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.

The team at work in the open-plan office
The firm’s founder at his desk in the Delhi office

How the work runs — quote first, then the work

  • Step 1: Documents first, questions second – We read the file before asking anything, so the questions we do ask are the ones that matter.
  • Step 2: A quote you can hold us to – Fixed in writing against a defined scope. No hourly meter, and no revision after the fact.
  • Step 3: The order of filing decided deliberately – Which return goes first can decide whether relief is available at all. That is planned, not discovered.
  • Step 4: Nothing filed without your sign-off – You see the completed work, ask what you need to, and approve it before submission.

Quoted up front, in writing.

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

Keep reading, sideways

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

Core services for this situation

Post-mortem planning & pipeline The full guide to post-mortem planning & pipeline, with the fee fixed before any work starts.
Form 15G / 15H — no-deduction declarations (India) Its own page: form 15g / 15h India — mechanism, deadlines and published fees.
TDS when buying property from an NRI (s.195) Everything on TDS when buying property from an NRI (s.195), at the same depth as this page.
Local resident director services in the US Resident director services USA — the guide, the FAQ and the fixed fee.
Form 1042 — annual withholding return The full guide to form 1042 annual withholding return, with the fee fixed before any work starts.
Business restructuring & exit charges Its own page: business restructuring & exit charges — mechanism, deadlines and published fees.
NRI selling property in India Everything on NRI selling property in India tax, at the same depth as this page.
Residency: 182/60+365 day tests (India) Residency: 182/60+365 day tests India — the guide, the FAQ and the fixed fee.
Expatriation tax (US s.877A) The full guide to expatriation tax (US s.877a), with the fee fixed before any work starts.

Who we bring this work to

Franchise owners — what you owe in each country The full guide to franchise owners what you owe in each country, with the fee fixed before any work starts.
Oil & gas rotational workers — what we charge Its own page: oil & gas rotational workers what we charge — mechanism, deadlines and published fees.
Construction & contracting — relief you're probably missing Everything on construction & contracting relief you're probably missing, at the same depth as this page.
Touring musicians — relief you're probably missing Touring musicians relief you're probably missing — the guide, the FAQ and the fixed fee.
Oil & gas rotational workers — your filing calendar The full guide to oil & gas rotational workers your filing calendar, with the fee fixed before any work starts.
Team-sport athletes — what you owe in each country Its own page: team-sport athletes what you owe in each country — mechanism, deadlines and published fees.
Tax for touring musicians Everything on touring musicians tax, at the same depth as this page.
Amazon FBA sellers — your filing calendar Amazon fba sellers your filing calendar — the guide, the FAQ and the fixed fee.
Tax for IT contractors The full guide to it contractors tax, with the fee fixed before any work starts.

Where our clients live and work

Ireland tax for expats — country guide The full guide to Ireland tax for expats, with the fee fixed before any work starts.
Peru tax for expats — country guide Its own page: Peru tax for expats — mechanism, deadlines and published fees.
Iceland tax for expats — country guide Everything on Iceland tax for expats, at the same depth as this page.
Turkey tax for expats — country guide Turkey tax for expats — the guide, the FAQ and the fixed fee.
Serbia tax for expats — country guide The full guide to serbia tax for expats, with the fee fixed before any work starts.
Romania tax for expats — country guide Its own page: romania tax for expats — mechanism, deadlines and published fees.
Canada–Germany tax corridor Everything on Canada Germany tax, at the same depth as this page.
Denmark tax for expats — country guide Denmark 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.

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

Incorporated consultant's arrangement reviewed for personal-services-business exposure

A consultant who incorporated to provide their own services to a single client needed the arrangement reviewed for personal-services-business risk, since incorporating to provide your own services can turn out to be the most expensive structure available. We reviewed the working relationship and set out the exposure the arrangement actually carried.

Case study 2

Corporation's client-relationship pattern adjusted to reduce personal-services-business risk

A corporation whose owner worked primarily for one client under conditions resembling employment needed the relationship pattern adjusted to reduce the risk of being classified as a personal services business. We reviewed the working arrangement and recommended changes that reduced the exposure going forward.

Case study 3

Multi-client consultant's structure confirmed safely outside personal-services-business risk

A consultant working through their own corporation for several clients at once wanted confirmation that their structure sat safely outside the personal-services-business rules before taking on an additional long-term engagement. We reviewed the client's full working pattern and confirmed the structure's position before the new engagement began.

Case study 4

One Employee Working From Another Country

A single remote employee can create payroll registration, withholding and social security obligations in their country, and sometimes a corporate presence too. The review sets out each obligation and the order they have to be registered in.

Read how this one runs
Case study 5

Indian Transfer Pricing Certification With a Hard Deadline

An Indian entity with international related-party transactions needs an accountant's report filed by a date of its own, ahead of the return. The work is reconciling the transactions to the books first, because the report is only as defensible as that reconciliation.

Read how this one runs
Case study 6

Treaty Relief Claimed on a Cross-Border Estate

The estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.

Read how this one runs
Case study 7

A Second Opinion on a Return Already Filed

A cross-border return prepared on one side only is usually right in isolation and wrong in combination. The review checks residence, source and relief in that order, and says plainly whether an amendment is worth making.

Read how this one runs
Case study 8

Information Returns Missed Behind a Correct Return

The heaviest exposure on a cross-border file is often a disclosure form rather than the tax. Where the return itself was right, the procedures for late information returns turn on a reasonable-cause narrative with dates and documents behind it.

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
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

Working from anywhere doesn't mean taxed nowhere: residency defaults, employer payroll exposure and treaty relief decide where income actually lands.

Working from another country does not by itself end tax residence in the one you left, and it can start one where you are sitting. Day counts, ties, the employer's own exposure and the treaty tie-breaker all point at the same question, and the year you move is the year it has to be answered on paper.

  • 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

Personal services business risk — questions we are asked

Personal services business risk — 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 corporation is effectively an incorporated employee, its income is taxed punitively and most expenses are disallowed.

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 makes a corporation a personal services business?

A corporation risks being treated as a personal services business when the individual providing services through it would, on the facts, look like an employee of the client rather than an independent contractor. Factors include control over how the work is done, whether the individual could reasonably be replaced by someone else, and whether they carry the ownership of tools and financial risk of an independent business. We test the arrangement against those factors before it is challenged rather than after.

Why does personal services business status change how income is taxed?

A corporation classified this way loses several deductions ordinarily available to a corporation, so its income is taxed closer to what an employee would pay, without employment benefits attaching to it. The gap between the two outcomes is often the whole reason the structure is worth reviewing early. We model both outcomes for a given contract before it starts so the individual understands the exposure rather than discovering it during a reassessment.

Can restructuring a contract reduce personal services business exposure?

Sometimes, though the contract wording is only one input; tax authorities look at how the relationship actually operates day to day, not just what the agreement says. We review the degree of control the client exercises, whether the individual can subcontract or bring on staff, and whether they bear meaningful business risk, then advise on changes that would genuinely shift the substance of the arrangement rather than only its paperwork.

Is moving money between my own accounts in two countries taxable?

Moving your own capital between your own accounts is not itself income, so the transfer is not what creates tax. What can create tax or reporting is the income the money earned before it moved, a foreign-exchange gain on certain holdings, and the reporting obligations the balances themselves trigger — foreign account and asset reports keyed to balances rather than income. Remittances out of some countries also need certification before the bank will send them. See foreign account reporting.

How do I actually stop being taxed twice?

In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.

15+ years of cross-border experience

Get personal services business risk 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.

  • A named reviewer signs off every filing
  • Rated 5.0 out of 5 stars on Google
  • Fixed fees agreed before work starts

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