Budget-friendly Students and trainees — the treaty article

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Student and trainee articles exempt maintenance payments and, in some treaties, limited local earnings — for a period that begins on arrival and does not restart. Budget-friendly students and trainees 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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  • 15+Years of cross-border experience
  • 18,000+Clients served
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  • 4Global offices — India, USA, Canada & UAE
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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
  • Google rating 5.0 out of 5
  • 18,000+ clients served
  • 15+ years of cross-border experience
The short answer

Student and trainee articles exempt maintenance payments and, in some treaties, limited local earnings — for a period that begins on arrival and does not restart. The relief is claimed, not automatic, and it usually requires a statement with the return.

Whether this is your situation

  • 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
  • A payer applied a statutory rate where a treaty rate was available
  • You need to prove residence to a foreign payer or authority

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.

The team at work in the open-plan office

Fixed fees for students trainees treaty article, agreed up front

The fee for claiming a student or trainee article turns on how many years are in front of you and whether there are local earnings as well as maintenance payments from home. A single year with a statement attached to the return is short work; years already filed without the claim have to be reopened one by one.

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

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
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

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

Payroll & mobility setup

From $999

fixed, quoted before work starts

Payroll set up for a workforce split across countries, including the relief that stops the same salary being withheld on twice.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The reporting obligations that attach to owning something abroad, worked out from your holdings rather than from the tax return alone.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Late and unfiled years, sequenced and filed together, with the relief available for the delay identified before the first return goes in.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

The transfer pricing file a group needs when goods, services or finance move between its own companies across a border.
See the fee schedule

All published fees on one page — every engagement, one list, no ranges hiding surprises.

Why the answer comes out the way it does

Student and trainee articles exempt maintenance payments and, in some treaties, limited local earnings — for a period that begins on arrival and does not restart.

The relief is claimed, not automatic, and it usually requires a statement with the return. Days excluded from residency counts and treaty-exempt income are separate reliefs that have to be claimed separately.

The consequence is that students and trainees — the treaty article 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.

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 non-resident receiving a Canadian pension and form 1041 — trust and estate return with foreign assets.

What we actually file

  • Eligibility analyses under the limitation-on-benefits and purpose tests
  • 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

Worked through with figures

Here is the rule doing its work on an actual set of amounts.

Credit relief on one stream of income

Take C$148,000 of income taxed in both countries. Assume the other country charged 19% on it and the home country would charge 28% on the same amount.

ItemAmount
Income taxed in both countriesC$148,000
Tax paid abroad (assumed 19%)C$28,120
Home tax on the same income (assumed 28%)C$41,440
Credit available (lesser of the two)C$28,120
Home tax still payableC$13,320

The credit absorbs C$28,120 and leaves C$13,320 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.

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.

The four steps

  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

Fees for this work

Fees for students and trainees — the treaty article 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.

  • Nothing is filed until you have read it.
  • Every statutory figure in your file is verified for your own year at source.
  • A named reviewer signs off every statutory filing.

Your next step

If a letter prompted this, bring the letter — it usually contains the answer to half the questions. 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.

Checked and signed off 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.

Tax treaty article, in practice

Most readers of this page are looking for tax treaty article. What follows sets out how it works for students and trainees: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

Student and trainee articles exempt maintenance payments and, in some treaties, limited local earnings — for a period that begins on arrival and does not restart.

The four phases of the work

  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.

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

Four terms worth pinning down

Non-willfulness certification
The signed narrative that is the substance of a streamlined submission. A story that contradicts the filings is what turns relief into an examination.
Totalization agreement
A social security agreement assigning coverage to one country and allowing contribution periods to be aggregated for benefits.
Protective return
A return filed to preserve deductions and treaty positions where the filer's conclusion is that no tax is owed. Filed late, the deductions can be lost entirely.
CbCR
Country-by-country reporting — a group-level template of revenue, profit, tax, people and assets by jurisdiction, exchanged between authorities and compared with local files.
students trainees treaty article: Our analysis

The relief is claimed, not automatic, and it usually requires a statement with the return.

Whatever the file turns out to involve, the terms do not move: the scope and the fee are agreed in writing before any work starts, a named practitioner reviews the result, and nothing is filed until you have approved it.

Students trainees treaty article — what the published fees look like

A second variable sits behind these fees: the exemption period runs from arrival and does not restart, so the file has to establish arrival dates, status changes and any earlier period spent in the country. Excluded days and treaty-exempt income are claimed separately, and a quote says which of the two is being prepared.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.

See this fee page

Individual tax filing

$349fixed, before work starts

Covers: Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.

See this fee page

Non-resident & departure filings

$349fixed, before work starts

Covers: Arrival and departure years priced as one engagement, with the part-year residence position and the assets deemed disposed of on exit.

See this fee page

The difference a dedicated cross-border team makes

18,000+ clients served

Individuals, expats and corporations across India, the USA, Canada and the UAE have filed with us — 15+ years of cross-border work.

The fee is fixed before we start

Quoted from your documents and agreed in writing. The number you accept is the number you pay.

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.

Cross-border is the whole practice

International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.

The firm’s founder at his desk in the Delhi office

How the engagement runs, phase by phase

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

How the work runs — quote first, then the work

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

Quoted up front, in writing.

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

Keep reading, sideways

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

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Tax on permanent residency The full guide to tax on permanent residency, with the fee fixed before any work starts.
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Who we help

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IT staffing firms cross-border tax Everything on it staffing firms cross border tax, at the same depth as this page.
Tax for freelance designers & writers Freelance designers & writers tax — the guide, the FAQ and the fixed fee.
Tax for individual athletes — tennis, golf The full guide to individual athletes — tennis, golf tax, with the fee fixed before any work starts.
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Tax for team-sport athletes Team-sport athletes tax — the guide, the FAQ and the fixed fee.
Professors & lecturers — your filing calendar The full guide to professors & lecturers your filing calendar, with the fee fixed before any work starts.
Tax for short-term rental hosts Its own page: short-term rental hosts tax — mechanism, deadlines and published fees.

Countries and corridors this work reaches

Lithuania tax for expats — country guide Its own page: lithuania 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.
Hong Kong tax for expats — country guide Hong Kong tax for expats — the guide, the FAQ and the fixed fee.
Cyprus tax for expats — country guide The full guide to Cyprus tax for expats, with the fee fixed before any work starts.
Chile tax for expats — country guide Its own page: Chile tax for expats — mechanism, deadlines and published fees.
Canada–UAE tax corridor Everything on Canada UAE tax, at the same depth as this page.
Spain tax for expats — country guide Spain tax for expats — the guide, the FAQ and the fixed fee.
Canada–Mexico tax corridor The full guide to Canada Mexico tax, with the fee fixed before any work starts.
Australia tax for expats — country guide Its own page: Australia tax for expats — 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

Files that look like this one

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

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 3

An Assignment Priced Without Counting the Days

Nearly every relief in a mobility file — treaty exemption, residence, social security — is decided by a day count that has to be evidenced. The engagement puts the tracking in place at the start, because it cannot be reconstructed at the end.

Read how this one runs
Case study 4

A Pension Taxed Where the Treaty Did Not Intend

Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.

Read how this one runs
Case study 5

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 6

Canadian Pension Paid Abroad and Taxed at the Flat Rate

Pension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.

Read how this one runs
Case study 7

Residency Changed Mid-Year and Both Returns Assumed a Full One

A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.

Read how this one runs
Case study 8

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

All case studies — every published engagement in one place.

Where we deliver this 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

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

Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.

Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.

  • 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

Students and trainees — the treaty article — questions we are asked

Students and trainees — the treaty article: is this a do-it-yourself job?

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 relief is claimed, not automatic, and it usually requires a statement with the return.

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.

Is a tax treaty the same thing as a totalization agreement?

No, and being covered by one says nothing about the other. An income tax treaty deals with income tax. A totalization or social security agreement deals with contributions — which country's social security system you pay into while working abroad, and how periods in two systems combine for benefit eligibility. Canada and the United States have both; plenty of country pairs have one and not the other. See totalization agreements.

What happens if the two countries disagree about which of them can tax me?

The treaty has a procedure for exactly that. You apply to the competent authority in your residence country, which takes the case up with its counterpart, and the two negotiate a position that removes the double taxation. Some treaties add binding arbitration if they cannot agree. It is slow and it runs on documents, so the practical work is preserving the record and filing protective claims while the clock runs. See our treaty work.

How do I claim a tax treaty benefit?

Three things usually have to line up: proof you are resident of the treaty country, a declaration to whoever is paying you so they withhold at the treaty rate rather than the statutory one, and the claim itself on the return of the country giving relief. Do it before the payment where a reduced rate is available — claimed afterwards it becomes a refund exercise instead, which takes far longer. See certificates of residency.

Can you review something another adviser prepared?

Yes, and that is a common engagement. A second opinion on a filed cross-border return most often finds an unclaimed credit, a missed information return, and a treaty position taken without the required disclosure.

What documents do you need to start?

The last two years of returns from each country involved, the slips or certificates for the income in question, and a note of dates — arrival, departure, or the transaction date.

Tax terms explained

Section 94 trustHypothetical taxBEPSAuthorised representativeForm 8938 thresholdWithholding taxTotalization agreementExemption methodW-8BENAirdropFDAP incomeAnnual information statementCustoms valuationGraduated rate estate Browse the full A–Z glossary

Related pages

Nearby pages

All treaties & withholdingCompetent authority / MAP requestTreaty relief on RRSP / 401(k) / IRALimitation on benefits — the treaty testUS 30 percent withholding and treaty ratesWithholding refund & recovery claimsBusiness profits and permanent establishment — Articles V and VII

Also relevant

Form 1065 — partnership return with foreign partnersCanada–India tax corridorForm 1040-X — amended returnCanadian with a US brokerage accountNon-resident with Canadian employment incomeForm 8288-A — FIRPTA statement

Answered questions

How does students and trainees, the treaty article work in practice?
15+ years of cross-border experience

Students and trainees — the treaty article, quoted before we start

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

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • 18,000+ clients served
  • Offices in India, the USA, Canada and the UAE
  • Fixed fees agreed before work starts

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068