Corporation Tax

A–Z of international tax terminology

Produced by Tolley
  • 21 Dec 2021 16:33

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
ATAD (anti-tax avoidance directive)ATAD is an EU directive which provides for a series of anti-abuse rules relating to interest expense deductions, controlled foreign companies and hybrid mismatches, and requires the introduction of a corporate GAAR and an exit tax (these two measures not being part of the BEPS project). ATAD II introduced further measures to combat hybrid mismatches, whilst ATAD 3 aims to limit the use of ‘shell’ holding

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