A–Z of international tax terminology

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

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.

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	Terminology	Definition	Further details
A	Amount A and Amount B	Part of the OECD’s package of measures to be introduced under Pillar 1 ― see ‘Pillar 1’ below
	Anti-conduit	Certain 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 entitled	DT19850PP
	Arm’s length arrangement	An 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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