A–Z of international tax terminology

Produced by Tolley

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

  • A–Z of international tax terminology
  • List of commonly used phrases in international tax

A–Z of international tax terminology

List of commonly used phrases in international tax

The table below lists some of the terminology commonly used in the context of corporate international tax and transfer pricing, together with links to additional sources of information including other guidance notes, Simon’s Taxes and HMRC’s manuals.

Navigation tip: press ‘Ctrl + F’ to search for a particular term within the table.

TerminologyDefinitionFurther details
AAnti-conduitCertain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where the amounts received are paid on to another company. This ensures that treaty benefits are only obtained by the contracting states, rather than residents of third countries who have deliberately arranged their transactions to obtain treaty benefits to which they would not otherwise be entitledDT19850PP
Arm’s length arrangementAn arm’s length arrangement reflects the price that would be payable and the terms which would be agreed for a transaction between unconnected parties. This is important for the purposes of the transfer pricing legislation (see ‘Transfer pricing’ below)Transfer pricing rules ― overview guidance note
Simon’s Taxes B4.147
INTM412040
ATCA (advance thin capitalisation agreement)An agreement with HMRC on the amount of interest which may be allowed in the corporation tax computation. It gives a degree of certainty to the company, its investors and future purchasers, enabling large groups to prepare their cashflow and tax forecasts with a greater level of accuracy. ATCAs are typically conditional on the borrower continuing to meet certain financial targets or covenantsCorporate debt ― overview guidance note
Simon’s Taxes B4.182
INTM520085
BBeneficial ownershipA company does not have beneficial ownership of income if it is required to pay it on to another company, eg if it receives it as a nominee. This has relevance in the context of transfer pricing.
May also be important in the context of reporting cross-border tax arrangementsunder the UK’s disclosable arrangementsrules, where one of the DAC 6 hallmarks in category D of Annex IV are satisfied
UK

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