Cross-border tax terms — B

Each entry answers two questions — what the term picks out, and what changes once it applies. Neither answer needs a number, and a number in a definition tends to outlive its accuracy.

Terminology is where cross-border risk hides. The rate is visible and gets checked; the classification is invisible and does not, which is why the classification is what usually goes wrong. So every entry is written in three parts: the meaning, the point at which it costs something, and the filings on this site that it governs.

If a term like this is in a notice you have received, bring the notice. The definition matters far less than what the sender is actually asking for. Every page here carries the name of the person who reviewed it and the date they did.

• Bona fide residence test — The other US qualifying test, satisfied by being a genuine resident of a foreign country for an uninterrupted period covering a full tax year.
• Beneficial ownership — The test that a treaty rate belongs to the person entitled to use and enjoy the income, not to an intermediary obliged to pass it on.
• Backup withholding — US withholding applied where a payee has not provided a valid taxpayer identification number or certification, independent of any treaty position.
• BEAT — The base-erosion minimum tax, which attacks deductible payments from a large US corporation to related foreign parties rather than the profit itself.
• Benchmarking study — A search for comparable companies or transactions producing a range against which a tested party's result is measured.
• Branch — A foreign operation that is the same legal person as the head office, so its results consolidate — at the cost of exposing the parent to the foreign system.
• Business purpose test — The requirement that a transaction have a commercial rationale beyond the tax result, documented at the time rather than reconstructed later.
• Business visitor — A short-term traveller whose exemption depends entirely on a day count nobody recorded.
• Black Money Act — India's statute on undisclosed foreign income and assets, with its own assessment powers, penalties and prosecution provisions outside the income tax act.
• BEPS — Base erosion and profit shifting — the international project whose outputs (country-by-country reporting, the multilateral instrument, the principal-purpose test) now condition treaty access and documentation for multinational groups.

What the B entries have in common

10 terms begin with B. What the entry under this letter turns on is set out on its own page, together with the returns it reaches and what we charge to handle them. Three to start with: Bona fide residence test, Beneficial ownership and Backup withholding.

Nearby letters

A — 13 terms · C — 25 terms. The full A–Z lists all 297 terms in one place.

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