What makes technology & saas different from an ordinary filing?
Software and subscription revenue is characterised differently across jurisdictions — as services, as royalties, or as a digital supply — and the characterisation changes both withholding and indirect tax. 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 cross-border tax work cost for a software company?
There is no list price, because the work is not the same from one group to the next. What drives the fee is the number of entities, the number of countries with an obligation, the number of open years, and how much of the underlying record already exists. A single company with one foreign customer base is a different piece of work from a group with engineers in three countries and several years unfiled. We read what you send before quoting, and the fee is agreed in writing before any work starts, so the figure you approve is the figure that applies to that scope. If you would rather talk it through first, the number is +1 (416) 619-0068.
Do you charge by the hour or a fixed fee?
A fixed fee, agreed in writing before the work begins. The reason is practical rather than promotional. Cross-border software work involves reading contracts and reconstructing history, and an hourly arrangement puts the cost of that uncertainty on the client, who is the person least able to price it. Fixing the fee moves the uncertainty to us, which means we have to scope properly before quoting rather than discover the shape of the file as we go. That is why we ask for documents up front. If the scope later turns out to include something nobody knew about, that is a separate piece of work and it is quoted the same way, in writing, before it starts.
What do you need from us before you can quote?
Enough to see the shape of the file. For a software business that usually means the corporate structure, the main customer agreements or a representative sample of them, where the people work, which countries have already asked you for something, and what has been filed to date. Management accounts help; audited figures are not needed. If returns are outstanding, we need to know for how long and in which country. From that we can say what the work consists of and put a price on it in writing. Sending an incomplete set is fine and is better than waiting, because the gaps themselves are usually part of what needs establishing.
Does the fee change if you find more filings later?
The agreed fee covers the agreed scope. If work comes to light that was not in that scope, for instance a country nobody had identified or years further back than we were told about, it is quoted separately and in writing before anything is done on it. You are not presented with an invoice larger than the one you approved for work you did not authorise. In practice the more complete the information at the quoting stage, the less often this arises, which is why the scoping questions are detailed. Where we can see a likely additional area at the outset, we say so and price it as an option rather than leave it to be discovered.
Is the quote for both countries or just one?
It covers whatever the engagement covers, and that is set out in the quote itself rather than left to be inferred. Most software groups that come to us need work in more than one country, and the value of having it done together is that the position taken in one return is consistent with the other and credits are claimed in the right order. Where a foreign filing is handled by another firm, the quote says so and describes what we would need from them. The point of putting the boundary in writing is that you can see exactly where it falls before you agree to anything.
Why does software revenue cost more to advise on than a straightforward return?
Because the answer is not in the accounts. A conventional return takes figures that already exist and puts them in the right places. Characterising subscription revenue means reading the agreements that produced it, establishing what each customer actually receives, and deciding what that means in each country involved. Where staff sit in several places there is a further layer about where the profit arises. That reading is the work, and better bookkeeping does not shorten it. Once it is done and documented, later years are usually cheaper, because the position already exists and only needs revisiting when the contracts change.
How does a remittance actually work, and is it taxed?
A remittance is a transfer of money, not a category of income, and moving your own funds between your own accounts is not what creates tax. What can create tax is the income behind the money and the rules of the country it leaves. India, for instance, collects tax at source when a resident individual remits abroad under the Liberalised Remittance Scheme, and requires certification before certain payments leave. The transfer is the trigger for paperwork rather than for tax. See the LRS and tax collected at source.
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.