What makes touring musicians different from an ordinary filing?
The performers article lets each country on a tour tax the income earned there, and promoters usually withhold at gross on the fee — including the share that funds the crew, the trucks and the production. 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.
Which country taxes my fee for a show abroad?
Generally the country where the performance took place. The performers article in most treaties lets each country on a tour tax the income earned there, which is why a single tour can create a filing obligation in every country it visits. Your home country usually taxes the same income as well, and then gives relief for the foreign tax. So the fee is not taxed once in a place of your choosing; it is taxed where it was earned, and the home return is where the two are reconciled.
Why did the promoter withhold tax on the crew's share?
Because promoters usually withhold at gross on the fee, not on your profit. The deduction is taken from the whole amount paid under the contract, including the share that funds the crew, the trucking and the production. Nothing in that mechanism looks at what the show cost you to put on. The practical consequence is that the tax taken routinely exceeds the tax actually due, and the difference only comes back if a claim is made in that country with the underlying costs evidenced.
Is merchandise income taxed the same as my show fee?
Usually not, and that is the trouble with settlement sheets that report them together. A performance fee is taxed under the rules that attach to performing in that country. Merchandise is a sale of goods, with its own sourcing, its own indirect tax questions and often the venue's commission taken before you see it. Treating the two as one line means the performance rules get applied to receipts they were never meant to cover, and the merchandise position is never examined at all.
Do I pay tax at home as well on foreign show income?
Normally yes, with relief then claimed for the tax already paid abroad. The home return brings in worldwide income, the foreign show fees included, and the foreign tax is credited against the home liability rather than ignored. Two things commonly go wrong. The relief is claimed on the amount withheld rather than the amount properly due, which overstates it. Or the foreign filings were never made, so there is no assessment to support the credit when the home revenue authority asks for one.
Does a support slot count the same as a headline show?
For this purpose, yes. The rule follows the performance in that country, not your billing on the poster, so a support slot, a festival appearance and a headline date all create the same kind of obligation. What differs is scale and paperwork. Smaller fees are often paid through a buyout or an agent with the deduction already made and nothing issued to evidence it, which makes the tax invisible until someone goes looking. Ask for the deduction evidence on every date, not only the big ones.
What if we played a country and never filed there?
The obligation does not expire because the tour moved on. In practice the file surfaces later — when a promoter is audited, when a refund claim is made, or when the home revenue authority asks what supports a foreign tax credit. The work then is to reconstruct what was played and paid in that country from itineraries and settlements, and to use whatever correction route the country offers. It is a slower and more expensive version of the filing that was skipped.
I have not filed for several years while living abroad — what are my options?
Both countries have routes back, and using one before they contact you is what preserves the relief. On the US side there are procedures aimed at taxpayers whose failure was not wilful, including one designed for people living outside the country, and separate procedures for late account reports and information returns alone. Canada has its voluntary disclosures programme and taxpayer relief for penalties and interest. Filing quietly and hoping is the one approach with no protection attached to it. See catch-up filing.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
