Fixed fees agreed before work starts – 18,000+ clients served
At Legal Quotient Consultants, we manage all your permanent establishment advisory requirements, from compliance to strategic planning. Our expert team ensures compliance, maximizes deductions, and optimizes your financial strategies so you can focus on growing your business. Economical Permanent Establishment Advisory for Cross-Border & Global Clients 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.
Fixed-Fee · Trusted · Accurate · Quick · Easy · Economical
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Stay compliant and optimize your financial processes with our specialized permanent establishment advisory services.
| Service | Includes | Fee | |
|---|---|---|---|
| Individual Cross-Border Tax | T1 + treaty coordination · Foreign income · Credits | FROM- $349 | Explore More |
| U.S. Tax Returns | 1040 / 1040-NR · State returns · FBAR | FROM- $449 | Explore More |
| Corporate International Tax | T2 + foreign affiliate · T1134 · Repatriation | FROM- $999 | Explore More |
| Transfer Pricing Documentation | Local file · Benchmarking · s.247 compliance | FROM- $2,500 | Explore More |
| Cross-Border Estate & Trust | Terminal returns · U.S. estate tax · Clearance | FROM- $799 | Explore More |
A permanent establishment is the treaty concept that decides whether a foreign company's business profits are taxable in a country. The classic forms are a fixed place of business — an office, a workshop, a branch — and a dependent agent who habitually concludes contracts or plays the principal role in concluding them; some treaties add a services permanent establishment where employees are present beyond a time threshold, and construction sites become one after a set duration. Preparatory and auxiliary activities are excluded, and independent agents acting in the ordinary course of their own business do not create one.
Once a permanent establishment exists, the profits attributable to it are taxed in that country as if it were a separate enterprise dealing at arm's length with the rest of the company, which brings transfer-pricing methods into the allocation. The advisory work is to review the actual pattern of activity — who is where, doing what, with what authority — against the treaty test, to restructure where the exposure is unintended, and to document the position so that a later enquiry is answered from the file rather than reconstructed.
Does an employee working from home in another country create a permanent establishment for us? It can, where the home office is at the company's disposal or the employee concludes contracts; a single employee working remotely for personal reasons often does not. The facts of the arrangement decide it, and they are documented.
We use a local distributor. Is that a permanent establishment? An independent distributor buying and reselling on its own account is not; a distributor that acts on your behalf and habitually concludes your contracts can be a dependent agent. The contract terms and the actual conduct both matter.
Permanent Establishment Advisory: Legal Quotient Consultants provides permanent establishment advisory for corporations operating, invoicing or owning subsidiaries across borders — planned and filed by cross-border specialists, with fixed fees agreed up front and every position explained before anything is submitted.
Send your documents securely through our portal or by email.
We prepare your permanent establishment advisory return and every supporting schedule.
You review each figure and approve before anything is filed.
We file with the CRA and send you the confirmation of receipt.
| Factor | Legal Quotient Consultants | Typical Firm |
|---|---|---|
| Pricing model | Fixed, flat fee | Hourly / unpredictable |
| Experience | 15+ years, 18,000+ clients | Varies |
| Helpline | 24 hours a day, +1 (416) 619-0068 | Office hours only |
| Where we work | Our offices in India, the USA, Canada and the UAE | One office only |
| CRA audit support | Included | Billed extra |
A warehouse, a dependent agent or a long project site can create a taxable presence abroad; PE analysis before contracts are signed keeps profits where you planned them.
Related-party cross-border pricing must satisfy the arm's-length principle; Canada's contemporaneous documentation rules (s.247) expose undocumented positions to transfer pricing penalties once adjustments pass the statutory threshold. Engagements are quoted as a fixed fee for a defined scope, and reviews of prior-year filings are included where earlier positions affect the current one.
Covers: The Canadian corporate return with the cross-border schedules that travel with it — foreign income, payments to non-residents, and the foreign affiliate flags.
What moves it up: The number of related-party transactions. A single management fee is manageable; a dozen intercompany flows brings the related-party return and transfer-pricing support with it.
See this fee pageCovers: 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.
What moves it up: How many people and places are involved. One employee working from home is one analysis; a sales team, a warehouse and a contractor with signing authority is several.
See this fee pageCovers: The foreign corporation's US return with the related-party information reporting, filed on time so deductions and treaty positions are preserved rather than argued for.
What moves it up: Dormancy is not a discount. A foreign-owned US entity with no activity still owes the information return, and the penalty for missing it does not scale with turnover.
See this fee pageProviding tailored permanent establishment advisory services to ensure compliance and maximize deductions.
Our cross-border tax accountants protect your business with complete federal and provincial tax compliance.
A dedicated team that handles your financials quickly and accurately, at a fixed fee agreed in writing before any work starts.
Dedicated preparation processes built around the countries each client files in.
Documents, questions and signatures in one portal, whichever country you are filing from.
Customized packages designed to grow as your business operations expand.
Start with a free, no-obligation consultation to review your business’s financial, tax filing and compliance needs and outline our affordable solutions.
Receive a comprehensive checklist and securely provide the required financial records and documents.
Our tax accountant and accounting experts carefully prepare your filings, identify all applicable deductions and credits, and conduct thorough reviews.
We file your documents electronically with the Canada Revenue Agency (CRA) on time and provide post-filing support.
Quoted up front, in writing.
Contact UsCA (India), CA (Malaysia)
CA (India)
FCA (India)
CPA (Canada), CPA (USA), CA (India)
CPA (Canada), CA (India)
Permanent Establishment Advisory starts at a fixed fee quoted before any work begins. The quote is locked at the outset and does not change mid-engagement, and you review the deliverable with us before it is filed. Compare every plan on our transparent pricing page.
At minimum: prior-year returns and notices of assessment, your bank and credit-card statements for the fiscal period, payroll records if you have employees, and GST/HST filings. We send a checklist tailored to your situation after the first call to our 24-hour helpline.
Most engagements are completed within 3 to 5 business days once your documents are complete. Catch-up work covering multiple years takes longer, and we tell you the realistic timeline before you commit rather than after.
We respond on your behalf at no extra charge for any return we prepared. Every figure we file is supported by documentation retained in your file, which is what turns a CRA review from a crisis into correspondence. See how our CRA audit support works.
Yes. The late-filing penalty is 5% of the balance owing plus 1% of that balance for each full month the return is late, to a maximum of 12 months (CRA, 2025 tax year). Interest is what compounds, daily, on top. We prioritise catch-up work and, where eligible, file under the CRA's Voluntary Disclosures Program to reduce penalties.
Yes. We work with clients wherever they live, from our offices in India, the USA, Canada and the UAE, and your location does not change the price or the service. Browse our coverage by country and region to find yours.
We work across construction, healthcare, e-commerce, professional services, restaurants, real estate, transportation, technology and non-profits, each with its own deduction profile and the points tax authorities scrutinise. See all industries we serve.
Software applies the rules you told it about. It does not ask whether a treaty caps the withholding on that payment, whether the foreign credit was claimed in the right country, whether an information return was due on an account that earned nothing, or whether your related-party pricing is documented. Those are the questions that move the number on a cross-border file.
Our permanent establishment advisory services include complete filing, compliance management, and strategic advice customized to Canadian tax laws.
You can start by calling our 24-hour helpline on +1 (416) 619-0068 or sending the form. We will review your files, provide a fixed quote, and start working immediately.
Usually the country you are physically in, because employment income is generally sourced where the work is done, with your residence country taxing it as well if you are resident there and giving credit. Three things follow: your employer may acquire withholding and social security obligations where you sit, a treaty tie-breaker may be needed if both countries call you resident, and a short trip that becomes a long stay can cross a residence threshold nobody was watching. See remote workers and digital nomads.
A branch is the same legal entity operating in another country, so its profits and losses sit with the parent and it is taxed there as a permanent establishment. A subsidiary is a separate company, taxed in its own right, with dividends and withholding on the way home. Losses, repatriation cost and liability usually decide it, and the answer differs by country pair. See branch vs subsidiary.
Still have questions? View our FAQ page or contact us.
A foreign company invoicing local customers through a small local sales team needed that presence reviewed for permanent-establishment risk before the team's activity expanded further. We reviewed the team's actual activities against the applicable treaty definition and set out the exposure the presence had already created.
A group whose local warehouse began performing light processing in addition to storage needed the facility reviewed, since a purely storage-based exemption stops applying once the activity performed there changes. We reviewed the warehouse's actual functions and confirmed whether the exemption still applied to the expanded role.
A group whose local representative had authority to conclude contracts on the parent's behalf needed that arrangement reviewed for the resulting permanent-establishment exposure it created for the parent company. We reviewed the agent's actual authority and set out the exposure it had created for the foreign parent.
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 runsA 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 runsA 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 runsThe 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 runsAn interest-free loan between related companies is priced as if it carried interest, and in some cases a deemed benefit follows as well. The file sets a rate against the borrower's own credit profile and documents the terms that support it.
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.
