Value-priced Franchise owners: relief you're probably missing

Cross-border tax advice and filing for franchise owners: your position assessed, the returns prepared, the fee fixed in writing before we start. Ask us about value-priced franchise owners: relief you're probably missing: call the 24-hour helpline on +1 (416) 619-0068, or request a written fixed quote today.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

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
  • Fixed fee agreed before work starts
  • 15+ years of cross-border experience
  • 24-hour helpline: +1 (416) 619-0068
In short

Franchise fees and royalties paid across a border are withheld at source under the royalty article, and the deductibility of the fee depends on transfer-pricing support where franchisor and franchisee are related.

Below: the rule, what clients ask first, two worked files with their numbers, the process end to end, and the published fee.

The rule that applies to this group and not the one next to it

Franchise fees and royalties paid across a border are withheld at source under the royalty article, and the deductibility of the fee depends on transfer-pricing support where franchisor and franchisee are related.

This is the point most filings get wrong. That is the practical value of a specialist here: not better arithmetic, but knowing which of several possible rules governs franchise owners before the return is built on the wrong one.

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

What franchise owners relief you're probably missing costs here

The relief most franchise owners miss is the treaty rate on royalties already withheld at source. What decides the fee is how many years of payments have to be reopened and whether the franchisor's certificates still exist, since a repayment claim the paperwork cannot support is not a claim. Agreed in writing before work starts.

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

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

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

Payroll & mobility setup

From $999

fixed, quoted before work starts

Employer registration and withholding for staff on assignment, arranged before the first pay run rather than corrected after it.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

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

Missed years brought current under the disclosure programme that fits, with the penalty position worked out before anything is filed.
See the fee schedule

Estate & trust filing

From $799

fixed, quoted before work starts

Trust and estate filings that reach across a border, including the reporting a foreign beneficiary or a foreign asset creates.
See the fee schedule

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

Three things we hear on the first call

  • My franchisor is abroad and the royalty withholding was never considered.
  • I own units in two countries under one holding company.
  • The franchise agreement was drafted for a domestic operator and I am not one.

None of those is unusual and none of them is a reason to be embarrassed. They are the normal consequence of a system that asks an individual to reconcile two sets of rules that were never designed to fit together. See also tax for pharmacists.

The numbers, end to end

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

Credit relief on one stream of income

Take C$177,000 of income taxed in both countries. Assume the other country charged 28% on it and the home country would charge 37% on the same amount.

Credit relief on one stream of income
ItemAmount
Income taxed in both countriesC$177,000
Tax paid abroad (assumed 28%)C$49,560
Home tax on the same income (assumed 37%)C$65,490
Credit available (lesser of the two)C$49,560
Home tax still payableC$15,930

The credit absorbs C$49,560 and leaves C$15,930 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. 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.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

The numbers, end to end

Worked through with figures, the mechanism looks like this.

Credit relief on one stream of income

Take C$82,000 of income taxed in both countries. Assume the other country charged 28% on it and the home country would charge 30% on the same amount.

Credit relief on one stream of income
ItemAmount
Income taxed in both countriesC$82,000
Tax paid abroad (assumed 28%)C$22,960
Home tax on the same income (assumed 30%)C$24,600
Credit available (lesser of the two)C$22,960
Home tax still payableC$1,640

The credit absorbs C$22,960 and leaves C$1,640 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.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

From first call to filed

  1. 1A short call to work out what actually applies to you and what does not
  2. 2A written quote against a defined scope, with nothing billed by the hour
  3. 3We prepare, a named reviewer checks it, and you see it before it goes
  4. 4You approve, we file, and only then do you pay
  • A change of scope is re-quoted before the work, never added to the invoice after it.
  • Nothing is filed until you have read it.
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.

Where to go from here

Send us the facts and we will tell you what has to be filed and what it costs.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Where international tax accountant comes into this file

Most readers of this page are looking for international tax accountant. What follows sets out how it works for franchise owners: relief you're probably missing: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

From first contact to filed return

  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

183-day rule
The common shorthand for a treaty employment article's presence test. There is no single rule — each treaty measures its own period on its own basis.
Reverse hybrid
An entity treated as a company by the country of establishment and as transparent by the investor's country, the mirror image of the classic hybrid.
Streamlined filing
The US catch-up route for non-willful filers, requiring a limited number of back returns and account reports plus a signed certification. Availability ends when the IRS makes contact first.
Compliance calendar
The mapped set of filings by entity and jurisdiction with an owner for each. Deadlines are missed because nobody owns the ones abroad, not because they are unknown.

Franchise owners relief you're probably missing — what the published fees look like

A second kind of relief sits on the deduction side. Where units in two countries sit under a single holding company, credits for tax already paid abroad can be stranded in the wrong entity, and the fees below reflect the work of tracing them back to the owner who can actually use them.

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.

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

Why clients bring franchise owners relief you're probably missing to us

A named reviewer on every file

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

We say early if it is not our work

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

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

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 team at work in the open-plan office

From first call to filed return

Step 1

Initial call

A call to the 24-hour helpline to find out whether this is a filing or a project

Step 2

Scope and fee

A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently

Step 3

Preparation and review

Preparation against the evidence, with the positions documented as we go

Step 4

Filing and payment

Your approval, then the filing — in that order

The team reviewing a file together at a desk

The engagement, start to finish

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

Quoted up front, in writing.

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

Where to go next

Browse sideways: the pages below answer the neighbouring questions.

Services these clients use most

Form 27Q — TDS on non-resident payments (India) The full guide to form 27q India, with the fee fixed before any work starts.
Form 8802 — US residency certification Its own page: form 8802 US residency certification — mechanism, deadlines and published fees.
Canada–India DTAA explained Everything on Canada India DTAA explained, at the same depth as this page.
Leaving Canada — departure (emigration) tax Canada emigration tax — the guide, the FAQ and the fixed fee.
Substance requirements in practice The full guide to substance requirements in practice, with the fee fixed before any work starts.
Tax risk register for cross-border groups Its own page: tax risk register for cross-border groups — mechanism, deadlines and published fees.
Delinquent information return procedures Everything on delinquent information return procedures, at the same depth as this page.
GST/HST registration — for non-residents, indirect tax Indirect tax — the guide, the FAQ and the fixed fee.
Cross-border wills The full guide to cross-border wills, with the fee fixed before any work starts.

Who we help

Tax for product & project managers The full guide to product & project managers tax, with the fee fixed before any work starts.
Tax for international school staff Its own page: international school staff tax — mechanism, deadlines and published fees.
Investors & property owners cross-border tax Everything on investors & property owners cross border tax, at the same depth as this page.
Influencers & content creators — what we charge Influencers & content creators what we charge — the guide, the FAQ and the fixed fee.
Advisors & referral partners cross-border tax The full guide to advisors & referral partners cross border tax, with the fee fixed before any work starts.
Professors & lecturers — relief you're probably missing Its own page: professors & lecturers relief you're probably missing — mechanism, deadlines and published fees.
Tax for nurses working abroad Everything on nurses working abroad tax, at the same depth as this page.
Tax for seasonal agricultural workers Seasonal agricultural workers tax — the guide, the FAQ and the fixed fee.
Media & production companies cross-border tax The full guide to media & production companies cross border tax, with the fee fixed before any work starts.

Where our clients live and work

Trinidad & Tobago tax for expats — country guide The full guide to Trinidad & tobago tax for expats, with the fee fixed before any work starts.
Colombia tax for expats — country guide Its own page: Colombia tax for expats — mechanism, deadlines and published fees.
Canada–Australia tax corridor Everything on Canada Australia tax, at the same depth as this page.
Canada–Netherlands tax corridor Canada Netherlands tax — the guide, the FAQ and the fixed fee.
Israel tax for expats — country guide The full guide to Israel tax for expats, with the fee fixed before any work starts.
Kenya tax for expats — country guide Its own page: Kenya tax for expats — mechanism, deadlines and published fees.
Germany tax for expats — country guide Everything on Germany tax for expats, at the same depth as this page.
Cayman Islands tax for expats — country guide Cayman islands tax for expats — the guide, the FAQ and the fixed fee.
Namibia tax for expats — country guide The full guide to namibia tax for expats, with the fee fixed before any work starts.

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

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 2

A Student or Researcher Covered by a Treaty Article

Several treaties carry a dedicated article for students, trainees and visiting researchers that displaces the ordinary employment rules. Whether it applies turns on the purpose of the stay and the source of the funds, both of which are evidenced rather than asserted.

Read how this one runs
Case study 3

Unreported Foreign Income Disclosed Before the CRA Asked

A voluntary disclosure has to be genuinely voluntary — once a letter arrives, the route usually closes. The engagement establishes whether the programme is still available, prepares the years, and puts the relief request in with the filing rather than after it.

Read how this one runs
Case study 4

Ten Years of Missed Returns Filed as One Engagement

Filing many years at once is a sequencing problem: carry-forwards, instalments and credits from the earliest year feed the latest. Filing them out of order is what turns a recoverable position into an assessed one.

Read how this one runs
Case study 5

Social Security Paid Twice Until a Certificate Arrived

Income tax relief does not reach a social security charge; only an agreement does, and only against a certificate from the system actually being paid into. Obtaining it is the work, and it is often retrospective.

Read how this one runs
Case study 6

Whether the Year Made Someone an NRI

Indian residence is decided by presence tests applied to the financial year, and a single trip can change the answer for the whole of it. The status is established before any return or exemption is considered.

Read how this one runs
Case study 7

Deemed Resident or Factual Resident — Not the Same File

The two statuses attract different returns, different credits and different provincial treatment, and the label is decided by facts rather than chosen. Establishing which applies is the work; the filing follows from it without argument.

Read how this one runs
Case study 8

An Assignment Priced on an Equalisation Promise

A policy that leaves the assignee no better or worse off has to be computed, not just stated, and the hypothetical deduction runs alongside the real one. The engagement builds both and reconciles them at year end.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

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

Franchise owners — relief you're probably missing — questions we are asked

What makes franchise owners different from an ordinary filing?

Franchise fees and royalties paid across a border are withheld at source under the royalty article, and the deductibility of the fee depends on transfer-pricing support where franchisor and franchisee are related. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.

Can you work with my existing accountant?

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

How does cross-border tax planning work?

It starts with facts rather than structures: which countries have a claim on you, what each one taxes, and where the two overlap. From there the decisions are about order and timing — which country taxes first, where relief is claimed, and whether a filing or a certificate has to be in place before money moves rather than after. Most of the value is in the sequencing, because relief claimed late is usually relief recovered slowly. See international tax planning.

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.

What happens after the filing?

You get the filed copies and a note of anything due next year, with the dates. Where an authority responds, that correspondence comes to us if the authorisation is in place.

Can a large engagement be split into stages?

For multi-year engagements, yes, agreed alongside the scope: each stage gets its own written number, and nothing outside the agreed stages is done without a new quote.

15+ years of cross-border experience

Let us take franchise owners filing off your desk

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.

  • A named reviewer signs off every filing
  • Rated 5.0 out of 5 stars on Google
  • 24-hour helpline, +1 (416) 619-0068

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