Cross-border tax terms — C

The definitions here are unnumbered on purpose. A concept survives a budget; a threshold does not, and the two are easy to confuse once they sit in the same sentence.

These words matter because tax systems are not built to line up. One country recognises a structure the other cannot see, and the filing that is routine at home becomes a disclosure obligation abroad. Every entry closes with the filings it touches, because a definition you cannot attach to a form is not yet useful.

Knowing the term is the first half. Knowing whether it applies to your year, and what evidence proves it, is the half that changes the outcome. Every page here carries the name of the person who reviewed it and the date they did.

• Closer connection — A statement that keeps someone who met the US presence test from being treated as a US resident, on the basis that their tax home and closer connections are in another country.
• Change of use — The point at which a property stops being a home and becomes a rental, or the reverse.
• Cessation of residence — The date the residence ties actually end.
• Certificate of residency — A document from a tax authority confirming residence for a period, required by a foreign payer or authority before it will apply a treaty rate.
• Carryback and carryforward — The mechanism that lets unused foreign tax credit be applied to another year rather than lost.
• Credit method — A relief method under which the residence country taxes the foreign income and allows the foreign tax against its own, up to its own tax on that income.
• Competent authority — The official body in each country empowered to apply and interpret a treaty, and to negotiate with its counterpart to resolve a case.
• Chapter 3 withholding — The US regime for withholding on US-source payments to foreign persons, operated through foreign-status certificates and recipient statements.
• Chapter 4 withholding — The FATCA withholding regime, which turns on an institution's or entity's status classification rather than on the character of the income.
• Controlled foreign affiliate — A foreign affiliate controlled by the Canadian taxpayer, alone or with related parties, whose passive income can be attributed to the shareholder currently.
• CFC — Controlled foreign corporation — the US concept whose earnings in defined categories are taxed to US shareholders before distribution.
• Country-by-country report — A group-level report of revenue, profit, tax, employees and assets per jurisdiction, exchanged between authorities and read alongside local files.
• Contemporaneous documentation — Transfer-pricing records prepared by the filing deadline rather than after a query.
• Comparable uncontrolled price — The most direct transfer-pricing method, using the price in a genuinely comparable third-party transaction.
• Cost plus method — A method testing the mark-up on costs earned by a manufacturer or service provider under limited risk.
• Corresponding adjustment — The matching adjustment in the other country that stops a transfer-pricing assessment taxing the same profit twice.
• Cost contribution arrangement — An arrangement in which participants share the cost and risk of developing something in exchange for a share of the benefit.
• Construction PE — A permanent establishment created by a building site or installation project lasting beyond the treaty's duration threshold.
• Central management and control — The test used to determine corporate and trust residence in several systems: where the strategic decisions are actually taken, not where the register is kept.
• Clearance certificate — Confirmation that all amounts owing by a deceased person and their estate have been paid.
• Customs valuation — The rules determining the value on which duty is assessed, related to but distinct from transfer-pricing rules on the same price.
• Certificate of coverage — The document evidencing which social security system applies to a cross-border worker.
• Clubbing of income — The Indian attribution of income back to a transferor where assets were transferred to a spouse or certain relatives without adequate consideration.
• Compliance calendar — The mapped set of filings by entity and jurisdiction with an owner for each.
• CbCR — Country-by-country reporting — a group-level template of revenue, profit, tax, people and assets by jurisdiction, exchanged between authorities and compared with local files.

What the C entries have in common

25 terms begin with C. The term below is defined in full on its own page, alongside the filings it governs and the fee for dealing with them. Three to start with: Closer connection, Change of use and Cessation of residence.

Nearby letters

B — 10 terms · D — 17 terms. The full A–Z lists all 297 terms in one place.

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