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A–Z of international tax terminology

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

A–Z of international tax terminology

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
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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
AAmount A and Amount BPart of the OECD’s package of measures to be introduced under Pillar 1 ― see ‘Pillar 1’ below
Anti-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

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