Reasonably priced Competent authority / MAP request

When two countries tax the same profit and neither will move, the treaty provides a government-to-government procedure — and it is available even where domestic appeal rights have run. Reasonably priced competent authority / MAP request 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 cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

Whatever documents you hold are enough to begin: we read them and put a fixed price in writing first.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • 24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
The short answer

When two countries tax the same profit and neither will move, the treaty provides a government-to-government procedure — and it is available even where domestic appeal rights have run. The request is made to the competent authority of the country of residence, within the treaty's time limit, and the two authorities then negotiate.

Whether this is your situation

  • Anti-abuse tests have never been applied to your treaty positions
  • Nobody owns the filing calendar for the foreign entities
  • A lender, buyer or investor has started asking tax questions
  • The board has never seen the group's tax exposures written down
  • Advice was taken years ago and the rules have moved since

Any two of those together and competent authority / MAP request is almost certainly your situation. If nothing on the list applies, the helpline call still costs nothing and we will redirect you.

The team reviewing a file together at a desk

Fixed fees for competent authority map request, agreed up front

A competent authority request is priced on how far the dispute has already travelled: whether the adjustment covers a single year or a run of them, whether the supporting file survives from the foreign audit or has to be rebuilt, and how many authorities end up in the negotiation. The fee is agreed in writing before the request is drafted.

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
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

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Intercompany pricing documented before it is questioned — the functional analysis, the benchmarking and the files that support it.
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

Corporate cross-border filing

From $999

fixed, 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

Payroll & mobility setup

From $999

fixed, 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

Estate & trust filing

From $799

fixed, quoted before work starts

The returns an estate or trust owes on each side, prepared together so relief for tax paid abroad is actually claimed.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

Non-resident filings and the two part-year returns a move produces, sequenced so neither country taxes the same income twice.
See the fee schedule

All published fees on one page — each engagement priced as one number on one list, with nothing left as a range.

How the rule actually works

When two countries tax the same profit and neither will move, the treaty provides a government-to-government procedure — and it is available even where domestic appeal rights have run.

The request is made to the competent authority of the country of residence, within the treaty's time limit, and the two authorities then negotiate. It is the standard route for a one-sided transfer-pricing adjustment or a contested residence determination.

The consequence is that competent authority / MAP request 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.

Because a wrong number is worse than no number, every rate and threshold in your file is confirmed for your year at source. Where that confirmation is not available in time, the advice states how the rule works and what would need checking, rather than filling the gap with an estimate. See also digital nomad with no fixed residence and non-resident with Canadian employment income.

What we actually file

  • A second-opinion memorandum on the existing arrangement
  • Implementation steps mapped to their deadlines
  • A written structure review with the positions and their support
  • The filing calendar, by entity and jurisdiction, with owners
  • The elections and disclosures the plan depends on

What this looks like with numbers

The same point, with figures rather than adjectives.

How an information-return exposure compounds

A filer who owed no tax at all, but missed an information return for 4 years with 1 form due each year. Assume a per-form penalty of US$4,000 for the illustration.

How an information-return exposure compounds
ItemAmount
Years unfiled4
Forms due per year1
Assumed penalty per formUS$4,000
Exposure before any reliefUS$16,000
Tax actually owed on the incomeUS$0

US$16,000 of exposure against nil tax. That asymmetry is why the disclosure routes exist and why the sequence of filings matters more than the arithmetic — filed in the right order under the right route, the penalty position can be very different from this. That is an illustration of the mechanism, not a prediction about your file — the same computation on your figures is the first thing we do.

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.

How we handle it

  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

Fees for competent authority / MAP request are quoted as a fixed amount for a defined scope. There is no hourly meter and no surprise on the invoice: the number is agreed in writing before anything starts. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A named reviewer signs off every statutory filing.
  • Documents move through one secure portal, and you can meet us in person at any of our offices.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.

How to get this moving

Whatever you have is enough to start the conversation, including nothing but the dates. Send whatever you have — even an incomplete set. Most of the first hour of a competent authority / MAP request engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.

US tax treaties, in practice

The search that brings most people to this page is US tax treaties. It is answered here for competent authority / MAP request: what creates the obligation, which filings discharge it, and the fee agreed before the work starts.

When two countries tax the same profit and neither will move, the treaty provides a government-to-government procedure — and it is available even where domestic appeal rights have run.

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.

How competent authority map request 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

Key terms behind this page, defined

Paid-up capital
The tax-recognised capital of a corporation, which determines how much can be returned to shareholders without a deemed distribution.
GILTI
Global intangible low-taxed income — a current US inclusion of a controlled foreign corporation's active earnings above a routine return on tangible assets.
Newcomer
Someone who has become resident during the year. Property held on arrival is generally treated as acquired at that day's value, which is why arrival-value evidence is worth keeping.
Closer connection
A statement that keeps someone who met the US presence test from being treated as a US resident, on the basis that their tax home and closer connections are in another country.
competent authority map request: The practitioner's note

The request is made to the competent authority of the country of residence, within the treaty's time limit, and the two authorities then negotiate.

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.

Competent authority map request — what the published fees look like

What else moves the price on a MAP file is the shape of the issue. A contested residence determination reads differently from a one-sided transfer-pricing adjustment, and keeping domestic appeal rights alive alongside the treaty route is additional work that is scoped and quoted separately rather than absorbed.

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

TP benchmarking study

$2,500fixed, before work starts

Covers: A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.

What makes it bigger: How defensible the comparables have to be. A study intended for a filing and a study intended to survive an audit are different pieces of work.

See this fee page

Why choose Legal Quotient for competent authority map request

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.

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.

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 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 firm’s founder at his desk in the Delhi office

From first call to filed return

Step 1

The opening call

A short call to work out what actually applies to you and what does not

Step 2

Scope in writing

A written quote against a defined scope, with nothing billed by the hour

Step 3

Prepared and checked

We prepare, a named reviewer checks it, and you see it before it goes

Step 4

Filed, then supported

You approve, we file, and only then do you pay

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

The engagement, start to finish

  • 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

Where to go next

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

The work we do for clients like this

Form 8865 — foreign partnership Its own page: form 8865 foreign partnership — mechanism, deadlines and published fees.
Keeping a home in Canada while abroad Everything on keeping a home in Canada while abroad, at the same depth as this page.
Shadow payroll Shadow payroll — the guide, the FAQ and the fixed fee.
Intercompany loan pricing The full guide to intercompany loan pricing, with the fee fixed before any work starts.
IP moved between countries Its own page: ip moved between countries tax — mechanism, deadlines and published fees.
Startup tax exemptions and angel tax Everything on startup tax exemptions and angel tax, at the same depth as this page.
NRE, NRO and FCNR accounts — how each is taxed NRE, NRO and FCNR accounts — how each is taxed — the guide, the FAQ and the fixed fee.
Notice of objection (Canada) The full guide to notice of objection Canada, with the fee fixed before any work starts.
Why a Canadian should rarely own an LLC Its own page: why Canadian should not own LLC — mechanism, deadlines and published fees.

Who we bring this work to

Technology & SaaS — what you owe in each country Its own page: technology & saas what you owe in each country — mechanism, deadlines and published fees.
Cross-border truck drivers — your filing calendar Everything on cross-border truck drivers your filing calendar, at the same depth as this page.
Tax for dentists Dentists tax — the guide, the FAQ and the fixed fee.
Media & production companies cross-border tax The full guide to media & production companies cross border tax, with the fee fixed before any work starts.
Tax for touring musicians Its own page: touring musicians tax — mechanism, deadlines and published fees.
Tax for construction workers abroad Everything on construction workers abroad tax, at the same depth as this page.
Airline pilots — relief you're probably missing Airline pilots relief you're probably missing — the guide, the FAQ and the fixed fee.
Tax for aid & ngo workers The full guide to aid & ngo workers tax, with the fee fixed before any work starts.
Seafarers & mariners — your filing calendar Its own page: seafarers & mariners your filing calendar — mechanism, deadlines and published fees.

Countries and corridors this work reaches

Estonia tax for expats — country guide Its own page: Estonia tax for expats — mechanism, deadlines and published fees.
Denmark tax for expats — country guide Everything on Denmark tax for expats, at the same depth as this page.
Algeria tax for expats — country guide Algeria tax for expats — the guide, the FAQ and the fixed fee.
Canada–Singapore tax corridor The full guide to Canada Singapore tax, with the fee fixed before any work starts.
Canada–United Kingdom tax corridor Its own page: Canada United Kingdom tax — mechanism, deadlines and published fees.
Hong Kong tax for expats — country guide Everything on Hong Kong tax for expats, at the same depth as this page.
US–Germany tax corridor US Germany tax — the guide, the FAQ and the fixed fee.
Austria tax for expats — country guide The full guide to Austria tax for expats, with the fee fixed before any work starts.
India–UAE tax corridor Its own page: India UAE tax — mechanism, deadlines and published fees.

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

An Adjustment in One Country and No Relief in the Other

A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.

Read how this one runs
Case study 2

An Indian Company Paying a Foreign Supplier

Payments abroad carry deduction at source and a certification filed before the money moves. Whether the treaty reduces the rate depends on what is being bought, and the classification is the decision the whole filing rests on.

Read how this one runs
Case study 3

Which Country Taxes the Salary

The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.

Read how this one runs
Case study 4

Two Passports, Two Returns, One Income

Dual citizenship does not let you choose which country taxes you. The work is establishing residence, applying the treaty article that governs each income type, and preparing both returns from one set of figures so they agree line for line.

Read how this one runs
Case study 5

Canadian Dividends and Interest Paid to a Non-Resident

Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.

Read how this one runs
Case study 6

A Taxable Presence Created Without an Office

A 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 runs
Case study 7

A Retirement Plan That Grows Tax-Deferred in Only One Country

Cross-border retirement accounts are recognised by treaty, but the deferral usually has to be elected rather than assumed. The engagement checks whether the election was made, makes it where it was missed, and reports the account on whichever side requires it.

Read how this one runs
Case study 8

An Estate That Cannot Distribute Until the Clearance Comes

An executor who distributes before the clearance certificate can be held personally liable for what is later assessed. The file prepares the final return and the estate return, and applies for the clearance in the order that lets the estate close.

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

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

Competent authority / MAP request — questions we are asked

Competent authority / MAP request — how much of this can I do 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: the request is made to the competent authority of the country of residence, within the treaty's time limit, and the two authorities then negotiate.

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.

Which country taxes my government pension or social security?

The treaty decides, and the answer differs by the type of retirement income. Many treaties give social security to the country of residence, sometimes exclusively, while a pension for government service can stay taxable only in the paying country. Some treaties also cap the taxable proportion or preserve an exemption the source country gives its own residents. Because the categories are distinct, one household can have two pensions taxed by two different countries. See the pensions and annuities article.

Does India have a tax treaty with the United States?

Yes. India and the United States have a comprehensive agreement covering residency, business profits, dividends, interest, royalties and fees for technical services, along with relief for the same income taxed in both. Claiming it from the Indian side generally means a residency certificate and Form 10F, and the credit itself is claimed on Form 67. See DTAA relief — India and the United States.

Is foreign pension income taxable in Canada?

Yes. A Canadian resident reports foreign pension income in Canadian dollars like any other income, and foreign tax withheld on it becomes a credit rather than a reduction of the amount reported. Where a treaty exempts part or all of it — some social security pensions are treated this way — the relief is claimed as a deduction on the return, not by leaving the pension off. Omitting it and claiming it was exempt are two very different filing positions. See the pensions and annuities article.

Is the quote binding?

Yes, for the scope quoted. A change in scope is re-quoted before the work continues, so there is never an invoice you have not already agreed to.

Do you keep my documents?

For the retention period the professional rules require, in the same access-controlled system, and no longer than that.

A named reviewer on every filing

A fixed fee for competent authority / map request

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

  • Rated 5.0 out of 5 stars on Google
  • A named reviewer signs off every filing
  • Your existing accountant keeps the domestic file

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