Affordable MLI & the principal-purpose test

Google Rating 5.0Clutch Rating 5.0

The multilateral instrument rewrote parts of hundreds of existing treaties at once, which means the treaty text you downloaded is not necessarily the treaty in force. Affordable MLI & the principal-purpose test 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.

+1 (416) 619-0068 See fixed fees
  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
Google Rating 5.0Clutch Rating 5.0

Secure a fixed quote

Send what you have. We price the engagement from your own documents, in writing, before any work starts.

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

The multilateral instrument rewrote parts of hundreds of existing treaties at once, which means the treaty text you downloaded is not necessarily the treaty in force. Its principal-purpose test denies a benefit where obtaining it was a principal purpose of an arrangement, unless granting it accords with the treaty's object.

Whether this is your situation

  • A treaty position needs to be claimed or disclosed on a return
  • The treaty text you are relying on may have been modified
  • An entity in the chain has never been tested against the eligibility rules
  • A withholding certificate on file has expired
  • One country has adjusted a position and the other has not followed

That list is deliberately concrete. If you recognise yourself in it, this page is the right starting point; if you do not, tell us and we will point you elsewhere without charging for it.

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

Transparent, fixed pricing for MLI principal purpose test

What sets the fee on principal-purpose-test work is how many treaties in the structure have to be read as modified by the MLI, with the reservations and notifications each country made checked in turn, and how many arrangements need a commercial-purpose record built.

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

Individual tax filing

From $349

fixed, 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

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

Non-resident & departure filings

From $349

fixed, quoted before work starts

Returns for the year you leave, the year you arrive, and the years you earn rental or pension income from a country you no longer live in.
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

Foreign asset & information reporting

From $349

fixed, quoted before work starts

Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Bringing an unfiled history current: which years are still open, which programme applies, and what the exposure is before you commit.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.
See the fee schedule

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

How the rule actually works

The multilateral instrument rewrote parts of hundreds of existing treaties at once, which means the treaty text you downloaded is not necessarily the treaty in force.

Its principal-purpose test denies a benefit where obtaining it was a principal purpose of an arrangement, unless granting it accords with the treaty's object. Checking the modified text, and the reservations each country made, is now part of every treaty position.

The practical reading of that is simple enough. Establish the position first, in writing; assemble the evidence that supports it; then prepare the filings in the order that lets the relief actually land. Doing those three in the other order is how the cost of MLI & the principal-purpose test multiplies.

Thresholds and rates move, and summaries written for last year are not evidence about this one. So each figure in your file is sourced to the issuing authority for the specific year; anything we cannot source, we describe as a mechanism and leave unquantified until it can be confirmed. See also dual citizen with two passports, two returns and Canada–Saudi Arabia tax corridor.

What we actually file

  • Correspondence with payers who applied the wrong rate
  • 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

The arithmetic, worked through

It is easier to see with numbers attached.

Credit relief on one stream of income

Take C$173,000 of income taxed in both countries. Assume the other country charged 31% on it and the home country would charge 26% on the same amount.

ItemAmount
Income taxed in both countriesC$173,000
Tax paid abroad (assumed 31%)C$53,630
Home tax on the same income (assumed 26%)C$44,980
Credit available (lesser of the two)C$44,980
Home tax still payableC$0

The credit fully absorbs the home liability on this income, so nothing further is payable at home — but the return still has to be filed and the credit still has to be claimed, by category and by country. 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.

From first call to filed

  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

What it costs

The commercial part is deliberately boring. One fixed fee for a written scope, agreed up front in writing — which is what lets us tell you honestly when MLI & the principal-purpose test is smaller than you feared. 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.
  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Consultations scheduled to your working day rather than ours.

Your next step

If a letter prompted this, bring the letter — it usually contains the answer to half the questions. Send whatever you have — even an incomplete set. Most of the first hour of an MLI & the principal-purpose test engagement is working out which documents actually matter, and that is quicker with a partial pack than with none.

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.

Where purpose of tax treaty comes into this file

If you came here for purpose of tax treaty, this is where it is dealt with. The subject is MLI & the principal-purpose test, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

The multilateral instrument rewrote parts of hundreds of existing treaties at once, which means the treaty text you downloaded is not necessarily the treaty in force.

How the engagement runs, phase by phase

  1. Start with a conversation about the facts

    Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.

  2. Scope and price, both written down

    You get the scope and the fixed fee together, so there is no question later about what was included.

  3. Prepared by one team, reviewed by a named practitioner

    The same people see both sides of the file, and the reviewer signs their name to it.

  4. Filed, then followed through

    Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

The vocabulary this page leans on

Second opinion
A review of a filed position, which most often finds an unclaimed credit, a missed information return and an undisclosed treaty position.
Dependent agent
A person who habitually concludes contracts, or plays the principal role leading to them, on behalf of a foreign enterprise — creating a taxable presence without premises.
US estate tax
A tax on the value of US-situs assets at death, reaching non-residents who never lived in the United States, with a much smaller exemption than a US person receives.
Implicit support
The benefit a group member gets from mere association with the group. It is not chargeable, which is why a guarantee fee is priced on the incremental benefit only.
MLI principal purpose test: How we read this one

Its principal-purpose test denies a benefit where obtaining it was a principal purpose of an arrangement, unless granting it accords with the treaty's object.

The engagement terms hold no matter what the analysis finds — fee and scope agreed in writing up front, a named reviewer on the output, your approval before the finished work is filed.

Fixed fees around MLI principal purpose test

Reviewing positions already taken runs differently from testing a structure before it is put in place: the first has to establish what each treaty actually said on every past payment date, since the modified provisions take effect on their own timetable country by country. Both are quoted in writing first.

Corporate cross-border filing

$999fixed, 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

Individual tax filing

$349fixed, before work starts

Covers: Personal returns for individuals, expats and non-residents — foreign income, foreign property and treaty relief handled in one engagement.

See this fee page

Non-resident & departure filings

$349fixed, before work starts

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

See this fee page

Why choose Legal Quotient for MLI principal purpose test

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

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 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.

Late and missed years are ordinary work

An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.

The team at work in the open-plan office

MLI principal purpose test — the four phases

Step 1

First conversation

We start with the chronology: dates, countries, and what has already been filed

Step 2

Written quote

You get the scope and the fee in writing before we touch anything

Step 3

Preparation and sign-off

The work is prepared and reviewed by a named person, not a queue

Step 4

Submission

Nothing is filed until you have read it

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

The engagement, start to finish

  • Step 1: Send what you already have – Slips, statements, prior returns — in any order. We list what is still needed after reading them.
  • Step 2: A fee agreed in writing – Quoted from those documents, before the work starts, and it does not move once you accept it.
  • Step 3: Each side drafted against the other – The returns are built together rather than in sequence, so relief is claimed once and in the right country.
  • Step 4: You approve before it is filed – The finished return comes to you first. Nothing is submitted on your behalf unseen.

Quoted up front, in writing.

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

The rest of this practice

Browse sideways: the pages below answer the neighbouring questions.

The work we do for clients like this

Why a Canadian should rarely own an LLC Everything on why Canadian should not own LLC, at the same depth as this page.
Cash pooling arrangements Cash pooling arrangements — the guide, the FAQ and the fixed fee.
Delinquent FBAR submission The full guide to delinquent FBAR submission, with the fee fixed before any work starts.
Indian company setting up in the US Its own page: Indian company setting up in the US — mechanism, deadlines and published fees.
Post-mortem planning & pipeline Everything on post-mortem planning & pipeline, at the same depth as this page.
Liaison office reporting and closure Liaison office reporting and closure — the guide, the FAQ and the fixed fee.
Functional & risk analysis The full guide to functional & risk analysis, with the fee fixed before any work starts.
Canada–India DTAA explained Its own page: Canada India DTAA explained — mechanism, deadlines and published fees.
Guarantee fee pricing Everything on guarantee fee pricing, at the same depth as this page.

Clients who arrive with this exact page

Professors & lecturers — relief you're probably missing Everything on professors & lecturers relief you're probably missing, at the same depth as this page.
Nurses working abroad — what we charge Nurses working abroad what we charge — the guide, the FAQ and the fixed fee.
Tax for civil & structural engineers The full guide to civil & structural engineers tax, with the fee fixed before any work starts.
IT contractors — your filing calendar Its own page: it contractors your filing calendar — mechanism, deadlines and published fees.
Civil & structural engineers — what we charge Everything on civil & structural engineers what we charge, at the same depth as this page.
Technology & SaaS cross-border tax Technology & saas cross border tax — the guide, the FAQ and the fixed fee.
IT contractors — relief you're probably missing The full guide to it contractors relief you're probably missing, with the fee fixed before any work starts.
Technology & SaaS — relief you're probably missing Its own page: technology & saas relief you're probably missing — mechanism, deadlines and published fees.
Software developers — relief you're probably missing Everything on software developers relief you're probably missing, at the same depth as this page.

Countries and corridors this work reaches

Philippines tax for expats — country guide Everything on Philippines tax for expats, at the same depth as this page.
Singapore tax for expats — country guide Singapore tax for expats — the guide, the FAQ and the fixed fee.
Germany tax for expats — country guide The full guide to Germany tax for expats, with the fee fixed before any work starts.
US–UAE tax corridor Its own page: US UAE tax — mechanism, deadlines and published fees.
New Zealand tax for expats — country guide Everything on New Zealand tax for expats, at the same depth as this page.
India–United Kingdom tax corridor India United Kingdom tax — the guide, the FAQ and the fixed fee.
Portugal tax for expats — country guide The full guide to Portugal tax for expats, with the fee fixed before any work starts.
China tax for expats — country guide Its own page: China tax for expats — mechanism, deadlines and published fees.
Zimbabwe tax for expats — country guide Everything on zimbabwe 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

Fifteen Per Cent Held Back From a Fee for Services in Canada

A 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 runs
Case study 2

The Same Income Taxed Twice on Paper

Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.

Read how this one runs
Case study 3

Deduction at Source on Deposit Interest, Recovered

Where the treaty rate is lower than what was deducted, the difference comes back through a return rather than at source. The file establishes entitlement and files for the years still open.

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

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 6

Trips That Added Up to a Filing Obligation

Short visits are tracked against a treaty threshold that is measured over a moving window rather than a calendar year. Where the threshold is passed, the obligation reaches back over the whole period.

Read how this one runs
Case study 7

Paying a Dividend Up to a Foreign Parent

The withholding rate depends on the treaty, on the size of the holding, and on whether the parent is the beneficial owner rather than a conduit. Establishing all three before the payment is what secures the lower rate at source.

Read how this one runs
Case study 8

A Country-by-Country Report and Who Files It

The obligation sits with the group and the filing can fall on a surrogate where the parent's jurisdiction does not exchange. Establishing who files where comes before preparing anything.

Read how this one runs

All case studies — every published engagement in one place.

How and where the work is delivered

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

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

Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.

Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.

  • 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

  • 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

MLI & the principal-purpose test — questions we are asked

MLI & the principal-purpose test — 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: its principal-purpose test denies a benefit where obtaining it was a principal purpose of an arrangement, unless granting it accords with the treaty's object.

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 is a totalization agreement and how do I use one?

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

Which countries have a tax treaty with the United States?

Around sixty, including Canada, the United Kingdom, India, Australia and most of western Europe — but the list matters less than the terms, because each treaty caps rates and allocates income differently. Two countries with treaties can produce opposite answers on the same pension or the same royalty. What decides your position is the specific article covering your income type. See our country guides.

Is my foreign pension taxable?

Usually in at least one country, and which one depends on the treaty article covering pensions — some give the taxing right to the country paying it, others to where you live, and several treat government service pensions differently again. Withholding at source is common and often reducible by treaty, with an elective return recovering an over-deduction. See the pensions article.

How do you decide what is out of scope?

It is written down before we start. Anything not named in the scope is quoted separately rather than assumed, which is what stops the fee moving.

How is the fee set?

It is agreed in writing before any work begins, based on the scope we establish on the first call. If the scope changes we re-quote before continuing — there is no hourly meter running in the background.

Tax terms explained

Engagement letterT106Business purpose testForm 26ASTax homeMarketplace facilitatorForm 926ApportionmentEstate tax treaty reliefNon-discrimination articleForm 8858Form 15CADay-count recordRepatriation Browse the full A–Z glossary

Related pages

Nearby pages

All treaties & withholdingWhich treaty wins when three countries applyDividends, interest and royalties — the treaty articlesCanada–India DTAA explainedTreaty relief on RRSP / 401(k) / IRACanada–UK, UAE and Australia treatiesRegulation 102 waiver

Adjacent services

NRI selling property in IndiaForm 8832 — entity classification electionForm 8802 — US residency certificationForm 8975 — country-by-country reportNRI with rental income in IndiaUS–Mexico tax corridor

Short answers

How does MLI & the principal-purpose test work in practice?
No hourly billing, ever

Get MLI & the principal-purpose test handled for a fixed fee

One short call, one fixed quote in writing, and your approval before anything is filed.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • Offices in India, the USA, Canada and the UAE
  • Re-quoted, never silently invoiced
  • A named reviewer signs off every filing

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