Cross-border business, defined.

A separate legal entity created to isolate the financial and legal risk around a specific asset, transaction, or investment. Because its liabilities are ring-fenced from the parent, an SPV is commonly used to hold property, intellectual property, or a single line of business.

A company whose main purpose is to own shares in other companies rather than trade in its own right. A holding structure centralises ownership, can simplify governance across a group, and may allow qualifying dividends and gains to pass between companies efficiently.

A financial free zone in Abu Dhabi that applies English common law directly and has its own courts and financial regulator. It is used for holding companies, funds, and family offices that need a common-law framework inside the UAE.

A company incorporated within a designated UAE economic zone that permits full foreign ownership and operates under the zone’s own licensing regime. Free zone entities are a common route for non-residents establishing a UAE presence.

An individual who ultimately owns or controls a UK company, typically by holding more than 25% of the shares or voting rights, or the right to appoint or remove directors. UK companies must identify their PSCs and record them at Companies House.

A firm registered with Companies House and supervised for anti-money-laundering purposes that is authorised to file information and verify identities on behalf of UK companies. The role was formalised under the Economic Crime and Corporate Transparency Act 2023.

The official statutory address of a company, used for legal correspondence from the registrar, tax authority, and courts. It must be a genuine address in the jurisdiction of incorporation where documents can be delivered and acknowledged.

A financial free zone in Dubai with its own common-law courts and independent regulator, running a legal system separate from the wider UAE onshore framework. It is used for funds, family offices, and foundations.

The Irish requirement that every company has at least one director resident in the European Economic Area. Where no director qualifies, the company must hold a statutory bond or show a real and continuous link to an activity in Ireland. Since Brexit a UK-resident director no longer satisfies the rule.

The shares a company issues and their nominal value, set at incorporation and changed only by formal steps. It fixes who owns what and, through unpaid capital, what shareholders can still be called on to pay.

A UAE company licensed by an emirate’s Department of Economic Development to trade directly in the local market, rather than within a free zone. Since 2021 most mainland activities allow full foreign ownership.

The transfer of a company’s registration from one jurisdiction to another without winding it up and forming a new entity, so the same legal person continues with its contracts and history intact. UAE common-law free zones such as the ADGM and DIFC allow companies to redomicile in.

The requirement that an entity claiming to be resident or active in a jurisdiction has genuine operations there, such as staff, premises, and decision-making, rather than existing only on paper. Substance rules determine whether a structure is respected for tax purposes.

A fixed place of business, or a dependent agent, through which a company carries on business in another country. Creating a PE can give that country the right to tax the profits attributable to it, even without a local company.

A foreign subsidiary whose profits may be attributed back to, and taxed in, the parent’s home country under anti-avoidance rules. CFC regimes are designed to stop profits being shifted into low-tax jurisdictions.

The test that decides which country has primary taxing rights over a company, usually based on where it is incorporated or where its central management and control sits. A company can be resident in more than one country, which double taxation agreements then resolve.

A treaty between two countries that allocates taxing rights and provides relief so the same income is not taxed twice. DTAs are central to structuring cross-border dividends, interest, royalties, and employment income.

The rules governing the price at which related companies in different countries transact with each other. Prices must reflect what independent parties would agree, the arm’s length principle, to prevent artificial profit shifting.

Tax deducted at source from cross-border payments such as dividends, interest, or royalties before they reach the recipient. The rate is often reduced by an applicable double taxation agreement.

A UK tax status for someone who is resident in the UK but treats another country as their permanent home. It has long affected how foreign income and gains are taxed.

A UAE free zone entity that meets the conditions to benefit from a 0% corporate tax rate on its qualifying income. Keeping that status depends on adequate substance, audited accounts, and staying within the qualifying activity rules.

The long-standing test that treats a company as tax resident where its real top-level decisions are actually made, rather than where it is registered. A founder who relocates but keeps controlling the company from the old country may not have moved its residence at all.

The federal corporate tax the UAE introduced in 2023, applying to business profits with a standard rate, a small-business relief for lower turnovers, and a zero rate on qualifying free zone income. An in-scope company must register and file a return even when no tax is payable.

The place where the key management and commercial decisions needed to run a company are, in substance, made. Many double taxation agreements use it as the tie-breaker to settle a single country of residence when a company would otherwise be resident in two.

A UK anti-avoidance regime that can tax a UK-resident individual on the income of an overseas company or structure they have transferred assets to, even where that income is kept offshore.

The OECD-led global minimum tax that seeks to ensure large multinational groups pay an effective rate of at least 15% in every country they operate in. Where the local rate is lower, a top-up tax can be charged elsewhere in the group.

An OECD transfer pricing concept for intangibles, standing for Development, Enhancement, Maintenance, Protection, and Exploitation. Profit from intellectual property should follow the entities that actually perform these functions, not the one that merely holds legal title.

An official certificate issued by the UAE Federal Tax Authority confirming that a person or company is tax resident in the UAE. It is used to claim relief under the UAE’s network of double taxation agreements.

The standard that transactions between related companies should be priced as if they were between independent parties. It is the foundation of transfer pricing rules across most jurisdictions and OECD guidance.

A loan between companies in the same group, often across borders, used to fund one company from another. The interest rate and terms have to be defensible, because tax authorities test them against what independent lenders would have agreed.

The UK framework for deciding whether an individual is tax resident in a given year, based on days spent in the UK combined with connecting factors such as family, work, and available accommodation. It replaced a largely case-law approach with a codified set of automatic and sufficient-ties tests.

A UK anti-avoidance rule that taxes certain income and gains realised during a short period of non-residence once the person resumes UK residence. It targets someone who leaves, takes a gain or distribution abroad, and returns within a set number of years.

A charge on unrealised gains that arises when a company or individual ceases to be tax resident in a country, treating the assets as sold at market value on departure. It stops accrued gains leaving the tax net simply because the taxpayer moves.

A UK exemption that removes the corporation tax charge on gains when one company sells a qualifying shareholding in another, broadly where it has held at least 10% of a trading company for a continuous period. It is what lets a UK holding company sell a subsidiary without a tax cost on the gain.

A relief that exempts qualifying dividends and share-disposal gains a company receives from its shareholdings, so profits are taxed once in the operating company rather than again in the holder. Many jurisdictions use it as the core of a holding-company regime.

A UK rule that lets HMRC counteract tax arrangements it regards as abusive, taxing them on a just and reasonable basis rather than as the taxpayer set them up. It is a backstop that sits behind the specific, targeted anti-avoidance rules.

A legal doctrine under which a court disregards documents that were never intended to create the rights they appear to, and looks instead at what the parties really agreed. A trust or arrangement found to be a sham is treated as if it had never existed.

The exemption at the heart of many controlled foreign company regimes: a foreign subsidiary that genuinely trades, and earns only a small fraction of passive or related-party income, has nothing attributed back to its parent. It is why a real operating business is usually left alone wherever it is based.

The mechanism of treating assets as sold at their market value when a person or company ceases to be tax resident, even though no sale has taken place. It is the engine behind exit taxes and emigration capital gains charges, turning a move abroad into a taxable event.

A UK rule that caps the income tax a non-resident pays on certain UK investment income, chiefly dividends, at the tax already deducted at source. Because the tax deducted on a dividend is nil, a shareholder who is non-resident for a whole tax year usually pays no further UK income tax on dividends from their UK company, in exchange for giving up the personal allowance.

New Zealand’s primary individual residence test: a person stays tax resident for as long as they keep a dwelling available to them as a permanent place of abode, and that connection overrides the day-count rule. Residence ends only when the person is both absent for more than 325 days in a twelve-month period and no longer has such a home.

A system, used in Australia and New Zealand, that attaches a credit to a dividend for the corporate tax the company has already paid, so the same profit is not taxed twice. A dividend carrying full credits is franked; the uncredited part can bear withholding tax when it is paid to a non-resident.

A rule that divides a tax year into a resident and a non-resident part when someone moves country partway through, so they are taxed as a UK or Irish resident only for the part of the year they actually were one.

A UK relief that reduces the Capital Gains Tax rate on the sale of a qualifying trading business or shares, up to a lifetime limit of £1 million of gains.

An Irish relief that taxes gains on the disposal of qualifying business assets at 10% instead of the standard 33%, up to a lifetime limit.

An Irish Capital Gains Tax relief on passing a family business to the next generation or selling it, available to owners from age 55.

An Irish relief that lets an employee relocating to Ireland exempt 30% of their employment income above a threshold from income tax, for up to five years.

Rules that stop taxpayers locking in an old, lower tax rate by signing contracts just before a rise. They can re-date or disapply arrangements entered mainly to beat an announced change.

The former UK regime under which a non-domiciled resident was taxed on foreign income and gains only when they were brought into the UK, rather than as they arose.

A UK Capital Gains Tax relief for outside investors who subscribe for new shares in an unlisted trading company and hold them for at least three years, up to a lifetime limit of £1 million of gains.

The lifetime limit on the value of an individual’s Irish pension funds before a penal tax charge applies to the excess. It shapes how much an owner-director can build up tax-efficiently in a pension.

The UK regime, in force from 6 April 2025, that lets a person in their first four years of UK tax residence claim relief on foreign income and gains after a long period abroad. It replaced the remittance basis with a shorter, residence-based relief.

The UK connecting factor, in force from 6 April 2025, that brings a person’s worldwide estate within inheritance tax once they have been UK resident for at least ten of the previous twenty tax years. It replaced domicile as the test for exposure to UK inheritance tax.

The framework of laws and controls that require regulated firms to detect and prevent the movement of illicit funds. AML obligations include customer due diligence, ongoing monitoring, and reporting suspicious activity.

The due-diligence process by which a regulated firm verifies a client’s identity, ownership, and source of funds before and during a relationship. KYC is the practical front line of anti-money-laundering compliance.

The natural person who ultimately owns or controls an entity, however many layers of ownership sit in between. Identifying the UBO is a core requirement of anti-money-laundering and corporate transparency regimes.

The UK requirement, introduced under the Economic Crime and Corporate Transparency Act 2023, for directors, PSCs, and those filing on behalf of companies to have their identity verified. Verification can be completed directly or through an Authorised Corporate Service Provider.

A regulated firm authorised to form companies and trusts and to provide related administration, such as arranging directors, secretaries, and registered offices. TCSPs are supervised for anti-money-laundering purposes.

Evidence of where the money for a specific transaction came from, such as a salary payment, a company distribution, or the proceeds of a sale. Regulated firms and banks ask for it before processing significant transactions.

Evidence of how a person’s overall wealth was built over time, rather than where a single payment originated. Banks, regulators, and buyers in a transaction each test it in their own way, and the strongest files are assembled long before anyone asks.

A deeper level of client checks applied where the risk is higher, for example with politically exposed persons or complex cross-border structures. It goes beyond standard verification to examine source of wealth and the purpose of the relationship.

An individual who holds or has held a prominent public position, together with their close associates and family members. Their profile calls for enhanced due diligence because of the higher risk of bribery or corruption.

A global framework under which financial institutions report account information to their tax authority, which then exchanges it automatically with other countries. In practice it means an account or structure in one jurisdiction is visible to the tax authority in another.

The US Foreign Account Tax Compliance Act, which requires financial institutions outside the United States to identify and report accounts held by US persons. It runs in parallel with the Common Reporting Standard used by most other countries.

The HMRC route for a UK taxpayer to voluntarily correct undeclared offshore income or gains from earlier years. Coming forward before HMRC opens an enquiry usually means lower penalties.

The annual filing every UK company must make to Companies House to confirm that its registered details, including directors, PSCs, registered office, and share capital, are up to date.

The statutory financial statements a company prepares for each accounting period and files with the companies registry, showing its financial position for the year. In the UK they go to Companies House, fall due nine months after the financial year end, and a dormant company still files them in a simpler form.

The corporation tax return a company files with the tax authority, reporting its taxable profit and the tax due. In the UK it is the CT600, filed with HMRC within twelve months of the accounting period end, while the tax itself falls due nine months and one day after that end.

A company that has had no significant accounting transactions in a period and is treated as dormant for filing purposes. Dormancy is a status that has to be maintained rather than an absence of obligation: the company still files a confirmation statement and dormant accounts, and must tell the tax authority it is dormant so that no return is expected.

The UK system by which an employer deducts income tax and National Insurance from wages and reports them to HMRC in real time on each pay run. Any company that pays a salary, including to its own director, has to operate it.

The official register on which a company records the individuals who ultimately own or control it. Examples are the UK PSC register, Ireland’s Register of Beneficial Ownership, and the UAE’s UBO register.

The UK register on which a non-UK entity that owns or buys UK property must record its beneficial owners before it can register title. It was created to remove the anonymity that overseas structures previously gave to UK real-estate ownership.

A legal arrangement in which a trustee holds and manages assets for the benefit of named beneficiaries under terms set by the person who created it. Trusts are used for succession, asset protection, and structured control of wealth across generations.

The structured arrangement of an individual’s assets to provide for succession, reduce tax on transfer, and reflect their wishes on death or incapacity. Cross-border estates need the rules of each relevant jurisdiction to be coordinated.

Lawful structuring of ownership to reduce the exposure of personal or family wealth to future creditors, litigation, or political risk. It relies on legitimate separation of assets, not concealment.

A private organisation that manages the investments, administration, and succession affairs of a single wealthy family or a small group of families. It coordinates the tax, legal, and reporting work that sits across the family’s entities and jurisdictions.

A civil-law wealth-holding structure that owns assets in its own name for a defined purpose or set of beneficiaries, sitting between a company and a trust. Foundations in the DIFC and ADGM give families the control and succession features of a trust within a civil-law structure.

A company a family owns to act as trustee of its own trusts, in place of an outside professional trustee. It gives the family control over trustee decisions, though that control carries its own tax residence and governance consequences.

A private company used to hold and grow family wealth, with different share classes allocated across generations. It is often compared with a trust as a way to pass value down while the founders retain a degree of control.

A life insurance policy used as a wrapper to hold investments, so growth is taxed under insurance rules rather than as it arises. Its efficiency depends on the policyholder not personally selecting the underlying assets and on meeting each jurisdiction’s rules.

A trust holding assets that sit outside the reach of UK inheritance tax, historically used by non-domiciled individuals for foreign assets. Recent UK reform has narrowed when the protection applies, which makes the timing of any change important.

Succession rules in many civil-law countries that reserve a fixed share of an estate for certain heirs, regardless of the will. Trust firewall legislation in centres such as the DIFC is designed to shield a trust from those claims.

An offshore trust set up by a non-domiciled individual before they became a long-term UK resident, which historically kept foreign income and gains outside UK tax until a benefit was taken. It is a central concept in older non-dom trust planning.

A UK tax charged on the value of a person’s estate on death, and on some lifetime gifts, above a tax-free threshold. The standard rate is 40% on the amount above the threshold.

A will registered through the DIFC Wills Service that lets a non-Muslim direct how their UAE assets pass on death, instead of the default local succession rules. It is a common tool for expatriates who own Dubai property.

Provisions in a trust jurisdiction’s law that direct its courts to apply local trust law, and to disregard foreign claims such as forced heirship or a foreign divorce order, when the validity of a local trust is challenged. They are the statutory shield behind offshore and free-zone trusts.

A trust whose governing law lets the person who created it keep defined powers, such as directing investments, without that reservation making the trust invalid. It gives a founder comfort in ceding legal ownership while retaining a measure of influence.

A UK inheritance tax relief that can reduce the taxable value of qualifying business assets, such as shares in an unquoted trading company or an interest in a trading business, by up to 100%. It is what lets a family business pass down without a forced sale to meet the tax.

A UK inheritance tax rule that keeps an asset inside a person’s estate where they give it away but carry on benefiting from it, such as gifting a home while still living in it rent-free. The gift does not work for tax until the benefit genuinely ends.

The legally tested ability to understand relevant information and make and communicate a particular decision when it is needed. When it is lost the person stays the legal owner of their assets and the holder of their offices but can no longer exercise any of them, so control freezes in place rather than passing to anyone.

An English instrument under which a person who still has capacity (the donor) appoints an attorney to manage their property and financial affairs, and which keeps working if the donor later loses capacity. The property and financial affairs power must be made while the donor has capacity and registered with the Office of the Public Guardian before it can be used.

The Irish instrument that lets a person appoint an attorney whose authority endures if they later lose capacity. Under the Assisted Decision-Making (Capacity) Act 2015 it is registered with the Decision Support Service and activates once notified, and the Act replaced the older wards-of-court system from 26 April 2023.

A document by which one person authorises another to act on their behalf. An ordinary power is an agency: it lets the holder act while the principal has capacity, but it terminates automatically on the principal’s death or loss of legal capacity, which is the exact moment continuity is most needed.

The England and Wales fallback where a person has already lost capacity with no lasting power in place: the Court of Protection appoints a deputy to act for them. It is slower, supervised, more costly and run by the court rather than by someone the family chose, which is the outcome a lasting power exists to avoid.

The UAE court process that takes over when a person loses capacity: the family applies for an interdiction order and the court, on medical evidence, appoints a guardian to manage the person’s affairs. While it runs, bank accounts and assets can be frozen and significant transactions need the court’s approval.