By Tolley

The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Glossary
  • Anti-conduit
  • Arm’s length price
  • Beneficial ownership
  • BEPS
  • Branch
  • Capital contribution
  • Controlled foreign company (CFC)
  • Credit relief
  • Deduction relief
  • Deemed capital contribution
  • Deemed distribution
  • Dependent agent
  • Domicile
  • Double tax agreement or double tax treaty
  • Effective management
  • Exemption relief
  • FDAP
  • Gross-up clause
  • GST
  • Holding company
  • Hybrid entity
  • Hybrid instrument
  • Interest box
  • Limitation on benefits
  • Management and control
  • Net worth tax or net wealth tax
  • OECD model tax convention
  • OECD transfer pricing guidelines
  • Patent box
  • Preparatory and auxiliary activities
  • Qualifying territory
  • Redomicile or reincorporate
  • Representative office
  • Resident
  • Residence certificate
  • Residence taxation
  • Sales tax
  • Secondary tax or a dividend distribution tax
  • Source
  • Source taxation
  • State taxes, local taxes or provincial taxes
  • Primary taxing rights and secondary taxing rights
  • Tie-breaker
  • Transfer pricing
  • Treaty clearance
  • Withholding tax
  • W8-BEN


Certain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where amounts received are paid on to another company.

Arm’s length price

An arm’s length price is the price which would be charged between unconnected parties. See the Establishing an arm's length price guidance note.

Beneficial ownership

A company does not have beneficial ownership of income if it is required to pay it on to another company, eg if it receives the income as a nominee.


The OECD Base Erosion and Profit Shifting (BEPS) initiative is considering a number of measures to combat perceived international tax avoidance.


A branch is an establishment of a company outside the country in which it is incorporated. Unlike a subsidiary company, it does not usually have separate legal personality, but it may need to be registered. See the Permanent establishment guidance note.

Capital contribution

In some countries, it is possible to make a capital contribution to a company, which increases its assets without increasing its share capital.

Controlled foreign company (CFC)

Controlled foreign company (CFC) rules are anti-avoidance rules which tax the profits of subsidiaries in their parent companies. See the Controlled foreign companies (CFCs) guidance note.

Credit relief

Credit relief is a form of double tax relief where the tax a company pays in the country where it is resident is reduced by overseas tax which it has suffered. See the Double tax relief guidance note.

Deduction relief

Deduction relief is a form of double tax relief where the taxable profits of a company are reduced by overseas tax which it has suffered. See

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