Low-cost Business profits and permanent establishment — Articles V and VII

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Under a treaty, a foreign business is taxable on its profits only to the extent they are attributable to a permanent establishment. Low-cost business profits and permanent establishment 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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Secure a fixed quote

First we read your documents, then you get the price in writing, and only then does the work begin.

24-hour helpline: +1 (416) 619-0068
  • Google rating 5.0 out of 5
  • 15+ years of cross-border experience
  • 24-hour helpline: +1 (416) 619-0068
The short answer

Under a treaty, a foreign business is taxable on its profits only to the extent they are attributable to a permanent establishment. The permanent-establishment article defines fixed places, dependent agents, construction sites and service presences, with carve-outs for preparatory activity.

Does this bind you?

  • A withholding certificate on file has expired
  • One country has adjusted a position and the other has not followed
  • Your relief was refused and you were not told which article failed
  • A third country has entered the picture and the two treaties disagree
  • Two countries are taxing the same income

One of those is usually enough to make this worth a conversation. If none of them fits, say so on the call and we will find the page that does.

The team reviewing a file together at a desk

Business profits permanent establishment article — priced before we start

The fee on a permanent establishment question depends on whether you need the threshold tested or the profits attributed once it is crossed. Testing one fixed place or one agent against the business profits article is contained work; attributing profit across a construction site, a service presence and a dependent agent is a larger exercise. Quoted in writing first.

PE / structure opinion — fixed-fee price

From $999

fixed, 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

Dual filing — 1040 + T1 together — fixed-fee price

From $449

fixed, quoted before work starts

Both returns prepared as one engagement, in the order the credit requires, so relief lands where it is usable rather than being claimed twice in the wrong place.
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

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

Benchmarking and documentation for related-party dealings, prepared to the standard the reviewing authority applies.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

The employer side of mobility — where to register, what to withhold, and what to report once someone works across a border.
See the fee schedule

Non-resident & departure filings

From $349

fixed, 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

fixed, quoted before work starts

Foreign holdings mapped once — accounts, real property, shareholdings — then reported to each authority in the form it requires.
See the fee schedule

All published fees on one page — the complete list of what each engagement costs, stated as figures rather than ranges.

The rule behind the paperwork

Under a treaty, a foreign business is taxable on its profits only to the extent they are attributable to a permanent establishment. Everything turns on that threshold and on the attribution that follows.

The permanent-establishment article defines fixed places, dependent agents, construction sites and service presences, with carve-outs for preparatory activity. Once crossed, profit attribution treats the establishment as if it dealt at arm's length with the rest of the enterprise.

This is why we start with a chronology rather than a form. Almost every position in this area is anchored to a date — of arrival, of departure, of a payment, of a transaction — and the evidence that supports it is either created around that date or reconstructed years later at several times the cost.

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 form 1040-x — amended return and form 7004 — business extension.

What we actually file

  • Confirmation of the treaty text actually in force for your year
  • Treaty-position disclosures on the return
  • Residency certificate applications and eligibility declarations
  • Waiver and reduced-withholding applications before payment
  • Refund and competent-authority claims where relief was denied

The numbers, end to end

Numbers make this concrete, so here is the same rule applied to a set of figures.

Credit relief on one stream of income

Take C$73,000 of income taxed in both countries. Assume the other country charged 22% on it and the home country would charge 27% on the same amount.

ItemAmount
Income taxed in both countriesC$73,000
Tax paid abroad (assumed 22%)C$16,060
Home tax on the same income (assumed 27%)C$19,710
Credit available (lesser of the two)C$16,060
Home tax still payableC$3,650

The credit absorbs C$16,060 and leaves C$3,650 payable at home, because the home rate on this income is the higher of the two. The balance is real cash and it is due on the home timetable, which is why instalments get raised in the first meeting. 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.

Example figures throughout, selected to make the rule visible, with rates and thresholds assumed for the demonstration. Your actual filing uses figures confirmed with the issuing authority for your tax year.

The four steps

  1. 1A first call to map the obligations across every country involved
  2. 2A single fixed fee covering the whole set, agreed before we begin
  3. 3Preparation in the order that makes the relief usable, with a reviewer's sign-off
  4. 4You approve the finished work, and we file it

What you pay, and when

What it costs is settled at the start. We establish the scope on a short call, quote a fixed fee against it in writing, and that is the number on the invoice. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • Authorisation with each authority, so we see the assessments and slips directly rather than asking you for them.
  • Nothing is filed until you have read it.

Your next step

The first call establishes whether there is work to do. Everything after that is quoted. 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.

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

Tax treaty article — what this page covers

The subject here is business profits and permanent establishment, which is what people mean when they search for tax treaty article. This page covers who it applies to, the filings it produces, and the fixed fee agreed before work begins.

Under a treaty, a foreign business is taxable on its profits only to the extent they are attributable to a permanent establishment.

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 business profits permanent establishment article

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

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.
Alter ego trust
A trust used to defer the death-year deemed disposition and avoid probate, which can be the wrong structure entirely where a US person is involved.
Fixed fee
A fee agreed in writing before the work begins. A change of scope is re-quoted rather than invoiced, which is what makes the number in the quote the number on the bill.
Part-year resident
Someone resident for only part of a tax year. Worldwide income is reported for the resident period and source income for the rest, with credits prorated to the resident portion.
business profits permanent establishment article: The practitioner's note

The permanent-establishment article defines fixed places, dependent agents, construction sites and service presences, with carve-outs for preparatory activity.

Whichever way the facts cut, you keep the same footing: a fee agreed in writing beforehand, a named practitioner reviewing the file, and nothing filed until the work is delivered and approved.

The published fees closest to business profits permanent establishment article

Records decide the rest of it. Where travel logs, contracts and site diaries already exist, the permanent establishment analysis is built from them; where presence has to be reconstructed years later, or one authority has already raised an assessment the other has not followed, the work grows accordingly.

Dual filing — 1040 + T1 together

$449fixed, before work starts

Covers: Both returns prepared as one engagement, in the order the credit requires, so relief lands where it is usable rather than being claimed twice in the wrong place.

What makes it bigger: Investment products. Local funds, tax-advantaged savings accounts and employer plans each need testing against the other system, and that is where a dual filing stops being two simple returns.

See this fee page

PE / structure opinion

$999fixed, before work starts

Covers: 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 makes it bigger: 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 page

T2 with foreign income

$999fixed, before work starts

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 makes it bigger: 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 page

Why choose Legal Quotient for business profits permanent establishment article

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.

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

A named reviewer on every file

Every page on this site and every file we deliver says which practitioner reviewed it — a person, not a team inbox.

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 team at work in the open-plan office

From first call to filed return

Step 1

First conversation

A call to our 24-hour helpline to establish the facts and the dates that matter

Step 2

Written quote

A written scope and a fixed fee before any work starts

Step 3

Preparation and sign-off

Preparation, then a named reviewer's sign-off before anything is filed

Step 4

Submission

Filing, then payment — after you have seen and approved the result

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

Each of these carries its own guide, pricing pointers and FAQ.

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Form T2091 — principal residence exemption: capital gains, foreign Its own page: principal residence exemption capital gains foreign property — mechanism, deadlines and published fees.
Form T2209 — federal foreign tax credit Everything on T2209 federal foreign tax credit, at the same depth as this page.
Study permit holders Study permit holders — the guide, the FAQ and the fixed fee.
Indian resident with foreign assets (Schedule FA) The full guide to Indian resident with foreign assets schedule fa, with the fee fixed before any work starts.
Form NR302 — partnership declaration Its own page: nr302 partnership declaration — mechanism, deadlines and published fees.
Form 3CEFA — safe harbour option (India) Everything on form 3cefa India, at the same depth as this page.

Who we bring this work to

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Crypto traders — your filing calendar The full guide to crypto traders your filing calendar, with the fee fixed before any work starts.
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Family holding companies cross-border tax Everything on family holding companies cross border tax, at the same depth as this page.
Airline pilots — what you owe in each country Airline pilots what you owe in each country — the guide, the FAQ and the fixed fee.
Touring musicians — your filing calendar The full guide to touring musicians your filing calendar, with the fee fixed before any work starts.
Nurses working abroad — relief you're probably missing Its own page: nurses working abroad relief you're probably missing — mechanism, deadlines and published fees.
Tax for product & project managers Everything on product & project managers tax, at the same depth as this page.

The corridors we work every week

Zimbabwe tax for expats — country guide Everything on zimbabwe tax for expats, at the same depth as this page.
Italy tax for expats — country guide Italy tax for expats — the guide, the FAQ and the fixed fee.
Oman tax for expats — country guide The full guide to Oman tax for expats, with the fee fixed before any work starts.
Ukraine tax for expats — country guide Its own page: Ukraine tax for expats — mechanism, deadlines and published fees.
Croatia tax for expats — country guide Everything on croatia tax for expats, at the same depth as this page.
US–Mexico tax corridor US Mexico tax — the guide, the FAQ and the fixed fee.
US–Germany tax corridor The full guide to US Germany tax, with the fee fixed before any work starts.
Thailand tax for expats — country guide Its own page: Thailand tax for expats — mechanism, deadlines and published fees.
Pakistan tax for expats — country guide Everything on Pakistan tax for expats, at the same depth as this page.

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

Cross-border tax case studies

Case study 1

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 2

One Salary, Two Countries Claiming It

A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.

Read how this one runs
Case study 3

Selling Into the US Without an Entity, and Filing in Several States

State obligations are set by each state, and a treaty does not reach them. The review measures activity against each state's own thresholds and separates the states where registration is required from the ones where it is not.

Read how this one runs
Case study 4

A US Citizen Settled in India, Filing on Both Sides

Residence in India and citizenship in the United States produce two annual returns for one income. The order decides the credit, and the Indian financial year and the US calendar year have to be reconciled before either is prepared.

Read how this one runs
Case study 5

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 6

A Canadian Landlord With Property in the United States

Gross withholding on US rents takes no account of mortgage interest, tax or repairs, so a leveraged property can face tax on turnover. An election onto net basis fixes that, and it has its own timing and its own filing.

Read how this one runs
Case study 7

A Canadian Employer With Staff in the United States

Employing someone in the US creates federal and state obligations that begin with registration, not with the first return. Which states are engaged is decided by where the work happens rather than where the company is.

Read how this one runs
Case study 8

A TFSA That Costs More Than It Saves

Canadian tax-free accounts are not tax-free to a US person, and some of them carry a reporting form of their own. The file is a review of what is held, what each account triggers on the US side, and whether the account is worth keeping once the reporting is priced in.

Read how this one runs

All case studies — every published engagement in one place.

Delivery, coverage and how we work

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

Where the work is delivered

More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
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

Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
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

Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
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

Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
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

Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
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

NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
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

T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
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

Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
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

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
Explore Real Estate

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

Business profits and permanent establishment — Articles V and VII — questions we are asked

Business profits and permanent establishment — Articles V and VII: what part of this actually needs a professional?

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 permanent-establishment article defines fixed places, dependent agents, construction sites and service presences, with carve-outs for preparatory activity.

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.

When does a construction project create a permanent establishment?

Most treaties give building sites and installation projects their own rule, turning on how long the work continues rather than on whether an office exists. Time is generally counted per site, and related contracts split between group companies are commonly aggregated to stop the threshold being avoided by paperwork. The period differs between treaties, so it is read from the one that applies. See permanent establishment risk.

What does Form W-8BEN actually do?

It tells a US payer that you are not a US person and, where you are entitled, claims the treaty rate on the income they are about to pay you — so withholding comes off at the reduced rate rather than the statutory one. It goes to the payer or the broker, never to the IRS, and it expires, so a stale form is a common cause of over-withholding. Getting it in before payment is the difference between a lower rate and a refund claim. See Form W-8BEN.

Should I use a branch or a subsidiary abroad?

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.

What if an authority disagrees later?

The file is built to be defended: the position, the authority relied on, and the evidence, all recorded at the time. Representation in a review or objection is quoted separately when it is needed.

Can you work alongside my existing accountant?

That is how most of our engagements run. They keep the domestic file, we take the cross-border piece, and the scope boundary is agreed in writing so nothing is done twice or missed.

Tax terms explained

Black Money ActWorldwide incomeSojourner ruleService PEStreamlined domestic offshoreCentral management and controlControlled foreign affiliateNRE accountClubbing of incomeZero-rated supplyTaxpayer reliefUS estate taxSurplus accountsClearance certificate Browse the full A–Z glossary

Related pages

Nearby pages

All treaties & withholdingSection 195 — TDS under a DTAA on Indian paymentsDividends, interest and royalties — the treaty articlesTie-breaking dual residency in practicePart XIII withholding reviewMLI & the principal-purpose testTreaty relief on RRSP / 401(k) / IRA

Where this leads next

Form 8840 — closer connection (snowbirds)US citizen in Canada — filing US taxes from abroadRNOR status — the two-year windowForm 1040 — filing from abroadForm 5472 — foreign-owned US corporationForm 2555 — foreign earned income exclusion

Short answers

How does business profits and permanent establishment work in
24-hour helpline: +1 (416) 619-0068

Talk to us about business profits and permanent establishment — articles v and vii

Tell us the situation and we quote in writing before any work starts. You approve the result before it is filed.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Your existing accountant keeps the domestic file
  • 24-hour helpline, +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE

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