---
title: "Cross-Border Business & Tax Glossary"
url: https://www.boruconsulting.com/glossary
type: DefinedTermSet
reviewed: 2026-10-06
---

# Cross-Border Business & Tax Glossary

> Plain-English definitions of the entity, tax, compliance and private wealth terms used across the UK, Ireland and the UAE. Each term links to its concept page; the complete typed graph is at https://www.boruconsulting.com/glossary.jsonld.

## Entities & structuring

- [Special Purpose Vehicle (SPV)](https://www.boruconsulting.com/glossary/special-purpose-vehicle): A separate legal entity created to isolate the financial and legal risk around a specific asset, transaction, or investment.
- [Holding Company](https://www.boruconsulting.com/glossary/holding-company): A company whose main purpose is to own shares in other companies rather than trade in its own right.
- [Abu Dhabi Global Market (ADGM)](https://www.boruconsulting.com/glossary/adgm): A financial free zone in Abu Dhabi that applies English common law directly and has its own courts and financial regulator.
- [Free Zone Company](https://www.boruconsulting.com/glossary/free-zone-company): A company incorporated within a designated UAE economic zone that permits full foreign ownership and operates under the zone’s own licensing regime.
- [Person with Significant Control (PSC)](https://www.boruconsulting.com/glossary/person-with-significant-control): 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.
- [Authorised Corporate Service Provider (ACSP)](https://www.boruconsulting.com/glossary/authorised-corporate-service-provider): 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.
- [Registered Office](https://www.boruconsulting.com/glossary/registered-office): The official statutory address of a company, used for legal correspondence from the registrar, tax authority, and courts.
- [Dubai International Financial Centre (DIFC)](https://www.boruconsulting.com/glossary/dubai-international-financial-centre): 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.
- [EEA-Resident Director](https://www.boruconsulting.com/glossary/eea-resident-director): The Irish requirement that every company has at least one director resident in the European Economic Area.
- [Share Capital](https://www.boruconsulting.com/glossary/share-capital): The shares a company issues and their nominal value, set at incorporation and changed only by formal steps.
- [Mainland Company](https://www.boruconsulting.com/glossary/mainland-company): 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.
- [Redomiciliation](https://www.boruconsulting.com/glossary/redomiciliation): 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.

## Cross-border tax

- [Economic Substance](https://www.boruconsulting.com/glossary/economic-substance): 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.
- [Permanent Establishment (PE)](https://www.boruconsulting.com/glossary/permanent-establishment): A fixed place of business, or a dependent agent, through which a company carries on business in another country.
- [Controlled Foreign Company (CFC)](https://www.boruconsulting.com/glossary/controlled-foreign-company): A foreign subsidiary whose profits may be attributed back to, and taxed in, the parent’s home country under anti-avoidance rules.
- [Corporate Tax Residence](https://www.boruconsulting.com/glossary/corporate-tax-residence): 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.
- [Double Taxation Agreement (DTA)](https://www.boruconsulting.com/glossary/double-taxation-agreement): A treaty between two countries that allocates taxing rights and provides relief so the same income is not taxed twice.
- [Transfer Pricing](https://www.boruconsulting.com/glossary/transfer-pricing): The rules governing the price at which related companies in different countries transact with each other.
- [Withholding Tax](https://www.boruconsulting.com/glossary/withholding-tax): Tax deducted at source from cross-border payments such as dividends, interest, or royalties before they reach the recipient.
- [Non-Domiciled Status (Non-Dom)](https://www.boruconsulting.com/glossary/non-domiciled-status): A UK tax status for someone who is resident in the UK but treats another country as their permanent home.
- [Qualifying Free Zone Person (QFZP)](https://www.boruconsulting.com/glossary/qualifying-free-zone-person): A UAE free zone entity that meets the conditions to benefit from a 0% corporate tax rate on its qualifying income.
- [Central Management and Control (CMC)](https://www.boruconsulting.com/glossary/central-management-and-control): 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.
- [UAE Corporate Tax](https://www.boruconsulting.com/glossary/uae-corporate-tax): 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.
- [Place of Effective Management (POEM)](https://www.boruconsulting.com/glossary/place-of-effective-management): The place where the key management and commercial decisions needed to run a company are, in substance, made.
- [Transfer of Assets Abroad (ToAA)](https://www.boruconsulting.com/glossary/transfer-of-assets-abroad): 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.
- [Pillar Two](https://www.boruconsulting.com/glossary/pillar-two): 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.
- [DEMPE](https://www.boruconsulting.com/glossary/dempe): An OECD transfer pricing concept for intangibles, standing for Development, Enhancement, Maintenance, Protection, and Exploitation.
- [UAE Tax Residency Certificate (TRC)](https://www.boruconsulting.com/glossary/uae-tax-residency-certificate): An official certificate issued by the UAE Federal Tax Authority confirming that a person or company is tax resident in the UAE.
- [Arm’s Length Principle](https://www.boruconsulting.com/glossary/arms-length-principle): The standard that transactions between related companies should be priced as if they were between independent parties.
- [Intercompany Loan](https://www.boruconsulting.com/glossary/intercompany-loan): A loan between companies in the same group, often across borders, used to fund one company from another.
- [Statutory Residence Test (SRT)](https://www.boruconsulting.com/glossary/statutory-residence-test): 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.
- [Temporary Non-Residence](https://www.boruconsulting.com/glossary/temporary-non-residence): 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.
- [Exit Tax](https://www.boruconsulting.com/glossary/exit-tax): 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.
- [Substantial Shareholding Exemption (SSE)](https://www.boruconsulting.com/glossary/substantial-shareholding-exemption): 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.
- [Participation Exemption](https://www.boruconsulting.com/glossary/participation-exemption): 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.
- [General Anti-Abuse Rule (GAAR)](https://www.boruconsulting.com/glossary/general-anti-abuse-rule): 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.
- [Sham](https://www.boruconsulting.com/glossary/sham): 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.
- [Active Income Test](https://www.boruconsulting.com/glossary/active-income-test): 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.
- [Deemed Disposal](https://www.boruconsulting.com/glossary/deemed-disposal): 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.
- [Disregarded Income](https://www.boruconsulting.com/glossary/disregarded-income): 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.
- [Permanent Place of Abode](https://www.boruconsulting.com/glossary/permanent-place-of-abode): 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.
- [Dividend Imputation](https://www.boruconsulting.com/glossary/dividend-imputation): 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.

## Reliefs & personal tax

- [Split Year Treatment](https://www.boruconsulting.com/glossary/split-year-treatment): 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.
- [Business Asset Disposal Relief (BADR)](https://www.boruconsulting.com/glossary/business-asset-disposal-relief): 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.
- [Revised Entrepreneur Relief](https://www.boruconsulting.com/glossary/revised-entrepreneur-relief): 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.
- [Retirement Relief](https://www.boruconsulting.com/glossary/retirement-relief): An Irish Capital Gains Tax relief on passing a family business to the next generation or selling it, available to owners from age 55.
- [Special Assignee Relief Programme (SARP)](https://www.boruconsulting.com/glossary/special-assignee-relief-programme): 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.
- [Anti-Forestalling](https://www.boruconsulting.com/glossary/anti-forestalling): Rules that stop taxpayers locking in an old, lower tax rate by signing contracts just before a rise.
- [Remittance Basis](https://www.boruconsulting.com/glossary/remittance-basis): 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.
- [Investors’ Relief](https://www.boruconsulting.com/glossary/investors-relief): 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.
- [Standard Fund Threshold (SFT)](https://www.boruconsulting.com/glossary/standard-fund-threshold): The lifetime limit on the value of an individual’s Irish pension funds before a penal tax charge applies to the excess.
- [Foreign Income and Gains Regime (FIG)](https://www.boruconsulting.com/glossary/foreign-income-and-gains-regime): 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.
- [Long-Term Residence](https://www.boruconsulting.com/glossary/long-term-residence): 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.

## Compliance & governance

- [Anti-Money Laundering (AML)](https://www.boruconsulting.com/glossary/anti-money-laundering): The framework of laws and controls that require regulated firms to detect and prevent the movement of illicit funds.
- [Know Your Customer (KYC)](https://www.boruconsulting.com/glossary/know-your-customer): The due-diligence process by which a regulated firm verifies a client’s identity, ownership, and source of funds before and during a relationship.
- [Ultimate Beneficial Owner (UBO)](https://www.boruconsulting.com/glossary/ultimate-beneficial-owner): The natural person who ultimately owns or controls an entity, however many layers of ownership sit in between.
- [Companies House Identity Verification](https://www.boruconsulting.com/glossary/companies-house-identity-verification): 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.
- [Trust and Company Service Provider (TCSP)](https://www.boruconsulting.com/glossary/trust-and-company-service-provider): A regulated firm authorised to form companies and trusts and to provide related administration, such as arranging directors, secretaries, and registered offices.
- [Source of Funds (SoF)](https://www.boruconsulting.com/glossary/source-of-funds): 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.
- [Source of Wealth (SoW)](https://www.boruconsulting.com/glossary/source-of-wealth): Evidence of how a person’s overall wealth was built over time, rather than where a single payment originated.
- [Enhanced Due Diligence (EDD)](https://www.boruconsulting.com/glossary/enhanced-due-diligence): A deeper level of client checks applied where the risk is higher, for example with politically exposed persons or complex cross-border structures.
- [Politically Exposed Person (PEP)](https://www.boruconsulting.com/glossary/politically-exposed-person): An individual who holds or has held a prominent public position, together with their close associates and family members.
- [Common Reporting Standard (CRS)](https://www.boruconsulting.com/glossary/common-reporting-standard): A global framework under which financial institutions report account information to their tax authority, which then exchanges it automatically with other countries.
- [FATCA](https://www.boruconsulting.com/glossary/fatca): The US Foreign Account Tax Compliance Act, which requires financial institutions outside the United States to identify and report accounts held by US persons.
- [Worldwide Disclosure Facility (WDF)](https://www.boruconsulting.com/glossary/worldwide-disclosure-facility): The HMRC route for a UK taxpayer to voluntarily correct undeclared offshore income or gains from earlier years.
- [Confirmation Statement](https://www.boruconsulting.com/glossary/confirmation-statement): 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.
- [Annual Accounts](https://www.boruconsulting.com/glossary/annual-accounts): The statutory financial statements a company prepares for each accounting period and files with the companies registry, showing its financial position for the year.
- [Company Tax Return (CT600)](https://www.boruconsulting.com/glossary/company-tax-return): The corporation tax return a company files with the tax authority, reporting its taxable profit and the tax due.
- [Dormant Company](https://www.boruconsulting.com/glossary/dormant-company): A company that has had no significant accounting transactions in a period and is treated as dormant for filing purposes.
- [Pay As You Earn (PAYE)](https://www.boruconsulting.com/glossary/pay-as-you-earn): 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.
- [Beneficial Ownership Register](https://www.boruconsulting.com/glossary/beneficial-ownership-register): The official register on which a company records the individuals who ultimately own or control it.
- [Register of Overseas Entities (ROE)](https://www.boruconsulting.com/glossary/register-of-overseas-entities): 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.

## Private wealth

- [Trust](https://www.boruconsulting.com/glossary/trust): 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.
- [Estate Planning](https://www.boruconsulting.com/glossary/estate-planning): The structured arrangement of an individual’s assets to provide for succession, reduce tax on transfer, and reflect their wishes on death or incapacity.
- [Asset Protection](https://www.boruconsulting.com/glossary/asset-protection): Lawful structuring of ownership to reduce the exposure of personal or family wealth to future creditors, litigation, or political risk.
- [Family Office](https://www.boruconsulting.com/glossary/family-office): A private organisation that manages the investments, administration, and succession affairs of a single wealthy family or a small group of families.
- [Foundation](https://www.boruconsulting.com/glossary/foundation): 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.
- [Private Trust Company (PTC)](https://www.boruconsulting.com/glossary/private-trust-company): A company a family owns to act as trustee of its own trusts, in place of an outside professional trustee.
- [Family Investment Company (FIC)](https://www.boruconsulting.com/glossary/family-investment-company): A private company used to hold and grow family wealth, with different share classes allocated across generations.
- [Private Placement Life Insurance (PPLI)](https://www.boruconsulting.com/glossary/private-placement-life-insurance): A life insurance policy used as a wrapper to hold investments, so growth is taxed under insurance rules rather than as it arises.
- [Excluded Property Trust](https://www.boruconsulting.com/glossary/excluded-property-trust): A trust holding assets that sit outside the reach of UK inheritance tax, historically used by non-domiciled individuals for foreign assets.
- [Forced Heirship](https://www.boruconsulting.com/glossary/forced-heirship): Succession rules in many civil-law countries that reserve a fixed share of an estate for certain heirs, regardless of the will.
- [Protected Settlement](https://www.boruconsulting.com/glossary/protected-settlement): 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.
- [Inheritance Tax (IHT)](https://www.boruconsulting.com/glossary/inheritance-tax): A UK tax charged on the value of a person’s estate on death, and on some lifetime gifts, above a tax-free threshold.
- [DIFC Will](https://www.boruconsulting.com/glossary/difc-will): 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.
- [Trust Firewall](https://www.boruconsulting.com/glossary/trust-firewall): 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.
- [Reserved Powers Trust](https://www.boruconsulting.com/glossary/reserved-powers-trust): 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.
- [Business Relief (BR)](https://www.boruconsulting.com/glossary/business-relief): 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%.
- [Gift with Reservation of Benefit (GWR)](https://www.boruconsulting.com/glossary/gift-with-reservation-of-benefit): 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.
- [Mental Capacity](https://www.boruconsulting.com/glossary/mental-capacity): The legally tested ability to understand relevant information and make and communicate a particular decision when it is needed.
- [Lasting Power of Attorney (LPA)](https://www.boruconsulting.com/glossary/lasting-power-of-attorney): 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.
- [Enduring Power of Attorney (EPA)](https://www.boruconsulting.com/glossary/enduring-power-of-attorney): The Irish instrument that lets a person appoint an attorney whose authority endures if they later lose capacity.
- [Power of Attorney (PoA)](https://www.boruconsulting.com/glossary/power-of-attorney): A document by which one person authorises another to act on their behalf.
- [Deputyship](https://www.boruconsulting.com/glossary/deputyship): 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.
- [Guardianship](https://www.boruconsulting.com/glossary/guardianship): 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.

## Situations (problem guides)

- [Moving from the UK to the UAE](https://www.boruconsulting.com/glossary/situations/moving-uk-to-uae): The common trap is running a UAE company from a UK desk: if the real decisions stay in the UK, the company can remain UK-taxed however it is registered.
- [Moving a company’s tax residence](https://www.boruconsulting.com/glossary/situations/moving-company-residence): Re-registering a company in the UAE is the easy part: its tax residence moves only if genuine control moves with it, and leaving the old country’s tax net can trigger a charge on the way out.
- [Setting up a UAE company](https://www.boruconsulting.com/glossary/situations/setting-up-a-uae-company): The licence is the easy part. Whether the company actually works turns on the free zone choice, genuine substance, and a bank that will open the account.
- [Selling or exiting your business](https://www.boruconsulting.com/glossary/situations/selling-your-business): Timing and structure decide the tax on exit, and a rushed contract can walk into anti-forestalling rules or surface as a problem in the buyer’s due diligence.
- [Passing wealth to the next generation](https://www.boruconsulting.com/glossary/situations/passing-wealth-to-the-next-generation): The right structure depends on where the family is resident, and a cross-border estate is taxed and inherited under more than one country’s rules at once.
- [Opening an account and proving your money](https://www.boruconsulting.com/glossary/situations/opening-an-account-and-proving-your-money): Banks and regulators test where the money came from and how the wealth was built, and the strongest file is assembled long before anyone asks for it.
- [Keeping a UK company compliant](https://www.boruconsulting.com/glossary/situations/keeping-a-uk-company-compliant): Identity verification and the annual filings are now actively enforced, and missing them is a common route to penalties or being struck off the register.
- [Hiring your first employee in another country](https://www.boruconsulting.com/glossary/situations/hiring-your-first-cross-border-employee): A single hire in another country opens a second payroll and tax system there, and if that person habitually closes deals in the company’s name they can give the company a taxable presence it never meant to create.
- [Planning for incapacity, not only death](https://www.boruconsulting.com/glossary/situations/planning-for-incapacity): A will moves control on death, but incapacity freezes it while the person still owns everything, and the English instrument that fixes it stops at the UAE border. The plan that survives is one where an entity governs the assets and each power has a named successor, put in place while capacity is intact.
- [Leaving a country that taxes your exit](https://www.boruconsulting.com/glossary/situations/leaving-a-country-that-taxes-your-exit): Some countries tax you on the way out, or for years after you go. Whether a move to Dubai triggers a charge, and whether a treaty softens it, turns on each country’s residence test and whether it deems your assets sold the day you leave.
- [Paying yourself from your company after you leave](https://www.boruconsulting.com/glossary/situations/paying-yourself-after-you-leave): Becoming non-resident changes how you are taxed on what you take out, not how your company is taxed on what it earns. The company stays put and keeps paying corporate tax, while dividends and salary are treated very differently once you live abroad.

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Full concept graph: https://www.boruconsulting.com/glossary.jsonld
Source: https://www.boruconsulting.com/glossary