What makes construction & contracting different from an ordinary filing?
Construction has its own permanent-establishment provision keyed to project duration, and subcontracting arrangements are aggregated in ways that surprise groups who thought each contract stood alone. 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 much does a cross-border filing for a construction company cost?
We do not publish one figure for it, because the work is driven by things visible in your documents rather than by the size of the company: how many sites, how many countries, whether a permanent establishment exists, whether the site accounts have to be rebuilt from scratch, how many people crossed a border and how well their days were recorded. So the sequence runs the other way round from a rate card. You send the contracts, the site dates and the payroll summary; we read them; you receive a fee in writing for a defined scope before any work starts. If you would rather talk it through first, the number is +1 (416) 619-0068.
What do you need from us before you can quote a price?
Enough to see the shape of the job. For a contracting group that usually means the project contracts, including any subcontracts on the same site, the mobilisation and demobilisation dates, a list of who attended and roughly when, the last statutory accounts, and any correspondence from a revenue authority. If a filing has already been made in either country, we want that too, whoever prepared it. We would rather read a rough bundle of original documents than a tidy summary written to explain them, because the summary is usually where the assumption that needs testing has already been quietly made.
Is the fee fixed if the project overruns and the filing grows?
The fee is fixed to a scope, and the scope is set out in the engagement letter in terms you can check against your own records. If the facts change — another country, another site, a year nobody mentioned, an enquiry opened after we started — that is new scope, and it is quoted in writing before it is done rather than appearing on an invoice afterwards. What does not move the fee is the work turning out harder than we expected inside the scope already agreed. That risk sits with us, which is the whole reason we quote from your documents rather than from a description of them.
Do you charge separately for each country we file in?
Usually yes, because they are separate pieces of work with separate deadlines, separate authorities and separate evidence behind them. What we do not do is treat them as separate engagements. The point of both countries being handled from one desk is that the position filed in one agrees with the position filed in the other, and that the relief claimed on one side mirrors what was assessed on the other. So the quote is broken down by filing and by country, priced together, and agreed in writing before anything begins.
What happens to the fee if the tax authority opens an enquiry?
An enquiry is quoted as its own piece of work, because nobody can scope it honestly before it exists. What we can do at the outset is tell you where the pressure points on your projects are likely to be — the duration evidence, the head-office allocation, the intercompany recharges — and price the work that makes those defensible now rather than under questioning later. If an enquiry does open, you get a written fee for responding to it, agreed before we reply, and we will say plainly where we think the cost of arguing is likely to exceed what is actually at stake.
Can you price the advice first and the filing later?
Yes, and for most contracting groups that is the better order. The advice answers the questions that determine everything else: whether the site crossed the threshold, whether subcontractor time is counted in, which country holds the taxing right, and what has to be filed at all. It is delivered as a written position. The filing work is then scoped against a known answer instead of a guess, which usually makes the second fee smaller and considerably more accurate than one combined figure quoted at the start, when nobody yet knew how many returns there would be.
What is a permanent establishment, and how easily do we create one?
A taxable presence in another country under the treaty — typically a fixed place of business such as an office, branch, factory or workshop, or a dependent agent habitually concluding contracts on your behalf. Some treaties add a services test measured in days. Purely preparatory or auxiliary activity is excluded, but that carve-out is narrower than it sounds: one senior employee working from home in the other country, with authority, has been enough. See business profits and permanent establishment.
How many days can I spend in a country before I become tax resident?
It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.
