Budget-friendly Treaty shopping & beneficial ownership

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Beneficial ownership is the test that stops a treaty rate being claimed by an entity that merely receives the money on someone else's behalf. Budget-friendly treaty shopping & beneficial ownership 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

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
  • 24-hour helpline: +1 (416) 619-0068
  • 18,000+ clients served
  • 15+ years of cross-border experience
The short answer

Beneficial ownership is the test that stops a treaty rate being claimed by an entity that merely receives the money on someone else's behalf. The question is whether the recipient has the right to use and enjoy the income rather than a contractual duty to pass it on.

Whether this is your situation

  • 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
  • Your relief was refused and you were not told which article failed

Most people who need help with treaty shopping & beneficial ownership tick at least two of those. If you tick none, we would rather tell you that on a call than take an engagement you do not need.

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

Fixed fees for treaty shopping beneficial ownership, agreed up front

Beneficial ownership work is priced on the chain, not the payment: how many entities sit between source and ultimate recipient, and whether each one's substance is already documented or has to be reconstructed from board records and contracts. A single holding company with clean records is a narrower review than a layered structure.

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

Company filings where income, ownership or operations cross a border, with the related-party disclosures that come with them.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

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

Accounts, property and company interests held outside the country of residence, reported on the schedules that carry penalties whether or not tax is owed.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Voluntary disclosure handled as one piece of work, from the review of what is outstanding to the returns that close it.
See the fee schedule

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

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

The rule behind the paperwork

Beneficial ownership is the test that stops a treaty rate being claimed by an entity that merely receives the money on someone else's behalf.

The question is whether the recipient has the right to use and enjoy the income rather than a contractual duty to pass it on. Combined with the principal-purpose test, it makes intermediate holding entities a substance question rather than a rate question.

Put the other way round: the return is the last step, not the work. What decides treaty shopping & beneficial ownership is the set of facts in place when the year closes, and those facts are the part a client can still influence when they come to us early enough.

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 Canadian selling US property — capital gains on the sale (FIRPTA) and accidental American who never filed US taxes.

What we actually file

  • 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
  • Credit computations by category and by country

What this looks like with numbers

Put numbers against it and the shape of the answer is obvious.

Credit relief on one stream of income

Take C$84,000 of income taxed in both countries. Assume the other country charged 21% on it and the home country would charge 31% on the same amount.

ItemAmount
Income taxed in both countriesC$84,000
Tax paid abroad (assumed 21%)C$17,640
Home tax on the same income (assumed 31%)C$26,040
Credit available (lesser of the two)C$17,640
Home tax still payableC$8,400

The credit absorbs C$17,640 and leaves C$8,400 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. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

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 establish what happened and when, because every position here is anchored to a date
  2. 2A written scope and a fixed price, so you know the cost before committing
  3. 3The filings are prepared, cross-checked against each other, and reviewed by name
  4. 4You see the result, approve it, and we file it

What it costs

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.

  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.
  • Fixed fees agreed before any work starts, so the number in the quote is the number on the invoice.

What to do next

If you already have an adviser, we will tell you what they should be asking rather than replacing them. The fastest start is a short call and three things: what happened, when it happened, and which countries are involved. Everything else we can ask for as it comes up.

Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.

Where tax treaty shopping comes into this file

Readers arrive here searching for tax treaty shopping, and treaty shopping & beneficial ownership is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.

Beneficial ownership is the test that stops a treaty rate being claimed by an entity that merely receives the money on someone else's behalf.

The four phases of the work

  1. Send what you already have

    Slips, statements, prior returns — in any order. We list what is still needed after reading them.

  2. A fee agreed in writing

    Quoted from those documents, before the work starts, and it does not move once you accept it.

  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.

  4. You approve before it is filed

    The finished return comes to you first. Nothing is submitted on your behalf unseen.

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

Key terms behind this page, defined

Engagement letter
The document setting the scope, the fee and the boundary with any other adviser. In a cross-border file the boundary is the important part.
Customs valuation
The rules determining the value on which duty is assessed, related to but distinct from transfer-pricing rules on the same price.
Hypothetical tax
The notional home-country tax deducted from an equalised assignee, standing in for what they would have paid had they not moved.
Hybrid mismatch
An outcome — a deduction with no inclusion, or a double deduction — arising from two countries classifying an entity or instrument differently. Anti-hybrid rules now neutralise it.
treaty shopping beneficial ownership: Our analysis

The question is whether the recipient has the right to use and enjoy the income rather than a contractual duty to pass it on.

Complexity changes the work, not the deal: the written fee and scope come first, a named practitioner signs off, and the filing follows your approval of the delivered file.

Fixed fees around treaty shopping beneficial ownership

The other thing that moves the fee is when you come to it. Testing a holding structure against the principal-purpose test before a payment is made is contained work; answering a payer or an authority that has already refused the treaty rate means assembling the same evidence under someone else's timetable.

Corporate cross-border filing

$999fixed, before work starts

Covers: The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.

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: The filings that follow a move: the departure year, the arrival year, and the income that keeps arriving from the country behind you.

See this fee page

The difference a dedicated cross-border team makes

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.

Filed with the authority, not just prepared

The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.

The quote comes from your documents

Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.

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.

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

Treaty shopping beneficial ownership — the four phases

Step 1

Establishing the facts

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

Step 2

Agreeing the fee

A written scope and a fixed fee before any work starts

Step 3

Drafting and review

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

Step 4

Filing and follow-up

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

The team reviewing a file together at a desk

The engagement, start to finish

  • Step 1: Share your documents – A secure upload link arrives after the first call — send files in any state.
  • Step 2: A written fixed fee – The quote is fixed from what you send; it does not move once accepted.
  • Step 3: Preparation, both sides at once – The returns are drafted together, reconciled line against line.
  • Step 4: Approve, then file – Nothing is filed until you have seen it and approved it.

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.

The work we do for clients like this

State residency & domicile forms Everything on US state residency domicile forms, at the same depth as this page.
IRS notice & CP letter response IRS notice cp letter response — the guide, the FAQ and the fixed fee.
Indian GST for foreign suppliers The full guide to Indian GST for foreign suppliers, with the fee fixed before any work starts.
Inheriting property in India Its own page: inheriting property in India — mechanism, deadlines and published fees.
Indian reassessment notices (s.148) Everything on Indian reassessment notice 148, at the same depth as this page.
Filing 10 years of missed returns Filing 10 years of missed returns — the guide, the FAQ and the fixed fee.
Keeping a home in Canada while abroad The full guide to keeping a home in Canada while abroad, with the fee fixed before any work starts.
Regulation 105 waiver Its own page: regulation 105 waiver — mechanism, deadlines and published fees.
Non-resident with Canadian employment income Everything on non-resident Canadian employment income, at the same depth as this page.

Who we bring this work to

Cross-border truck drivers — what you owe in each country Everything on cross-border truck drivers what you owe in each country, at the same depth as this page.
Tax for airline pilots Airline pilots tax — the guide, the FAQ and the fixed fee.
Agriculture & agri-tech cross-border tax The full guide to agriculture & agri-tech cross border tax, 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.
Food & beverage brands cross-border tax Everything on food & beverage brands cross border tax, at the same depth as this page.
Tax for franchise owners Franchise owners tax — the guide, the FAQ and the fixed fee.
Software developers — what we charge The full guide to software developers what we charge, with the fee fixed before any work starts.
Tax for adult-platform creators Its own page: adult-platform creators tax — mechanism, deadlines and published fees.
AI & deep-tech startups cross-border tax Everything on ai & deep-tech startups cross border tax, at the same depth as this page.

Countries and corridors this work reaches

Singapore tax for expats — country guide Everything on Singapore tax for expats, at the same depth as this page.
Canada–United Kingdom tax corridor Canada United Kingdom tax — the guide, the FAQ and the fixed fee.
Ukraine tax for expats — country guide The full guide to Ukraine tax for expats, with the fee fixed before any work starts.
Canada–Netherlands tax corridor Its own page: Canada Netherlands tax — mechanism, deadlines and published fees.
Kazakhstan tax for expats — country guide Everything on kazakhstan tax for expats, at the same depth as this page.
Poland tax for expats — country guide Poland tax for expats — the guide, the FAQ and the fixed fee.
France tax for expats — country guide The full guide to France tax for expats, with the fee fixed before any work starts.
Spain tax for expats — country guide Its own page: Spain tax for expats — mechanism, deadlines and published fees.
Austria tax for expats — country guide Everything on Austria 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

Three Countries in One File and Two Treaties That Disagree

Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.

Read how this one runs
Case study 2

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 3

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 4

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 5

Green Card Kept, Moved to Canada — Both Returns Still Due

Holding a green card does not end the US filing obligation, and living in Canada starts a Canadian one. The engagement fixes residence under the treaty tie-breaker, then decides which return the relief is claimed on so the two do not contradict each other.

Read how this one runs
Case study 6

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 7

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 8

A Foreign Subsidiary That Nobody Had Been Reporting

Owning a company abroad triggers an information return separate from the corporate return, with its own penalty. The work is the surplus and income computations behind it, which also determine how a future dividend is taxed on the way home.

Read how this one runs

All case studies — every published engagement in one place.

Where we deliver this work

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

  • 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

Treaty shopping & beneficial ownership — questions we are asked

Treaty shopping & beneficial ownership — 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 question is whether the recipient has the right to use and enjoy the income rather than a contractual duty to pass it on.

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.

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.

How does an NRI prove residence to get the treaty rate?

With a tax residency certificate issued by the country you are resident in, plus Form 10F giving the details the certificate does not carry, plus a PAN in the payer's records. The certificate has to cover the period of the payment, and the payer needs it before paying, not afterwards. Missing any of the three and the deductor is obliged to withhold at the domestic rate, which turns a rate reduction into a refund claim. See TRC against Form 10F.

What if the answer is that I do not need you?

Then we say so on the call, and the call costs nothing. It happens often enough that we would rather you asked than assumed.

What if my situation changes mid-year?

Tell us when it happens rather than at filing. Most of what we can do about a change is available in the weeks around it and not afterwards.

Tax terms explained

Advance rulingMark-to-market electionFixed feeT1135Saving clauseFBARLimitation on benefitsZero-rated supplyFIRPTAEconomic double taxationReassessment noticeExchange of informationMarketplace facilitatorFDII Browse the full A–Z glossary

Related pages

Related in this section

All treaties & withholdingArtistes and sportspersons — the treaty articleTreaty residency tie-breaker (Article IV)Canada–UK, UAE and Australia treatiesBusiness profits and permanent establishment — Articles V and VIIStudents and trainees — the treaty articleSocial security totalization agreements — Canada and the US

Where this leads next

Foreign income subject to self-employment taxDeemed resident vs factual residentForm 14653 — non-resident certificationForm 8621 — PFICCanada–Netherlands tax corridorNRI with rental income in India

Answered questions

How does treaty shopping & beneficial ownership work in practice?
Meet us in person at any of our offices

Ready to deal with treaty shopping & beneficial ownership?

One call to the 24-hour helpline is enough to tell you what has to be filed, what it costs, and whether you need us at all.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • 24-hour helpline, +1 (416) 619-0068
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  • 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.

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