Cross-border tax terms — E

Every definition here is written at mechanism level: what the term means and what turns on it. No threshold, rate or day-count is quoted in a glossary entry, because a stale number in a definition is the one most likely to be copied into a filing.

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.

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.

• Emigrant — Someone who has ceased to be resident.
• Effectively connected income — US-source income connected with a US trade or business, taxed on a net basis at graduated rates on a return rather than by flat gross withholding.
• Economic double taxation — The same profit taxed in two hands — typically after a transfer-pricing adjustment in one country with no corresponding adjustment in the other.
• Exemption method — A relief method under which the residence country does not tax the foreign income at all, rather than taxing it and giving credit.
• Exchange of information — The treaty and multilateral machinery by which tax authorities share account and taxpayer data.
• Exempt surplus — A pool of a foreign affiliate's active business earnings from a treaty or agreement country, dividends from which can generally reach Canada without further Canadian tax.
• Excess distribution — A distribution from a foreign pooled investment above a permitted amount, thrown back across the holding period with an interest charge under the default regime.
• Exit charge — A payment for value transferred when functions, assets or risks are moved out of a jurisdiction in a restructuring.
• Earnings stripping — Rules limiting interest deductions by reference to earnings, operating alongside or instead of a debt-to-equity test.
• Economic substance — The requirement that an entity have real people, decisions and functions in its jurisdiction.
• Economic nexus — A sales-tax connection created by revenue or transaction volume into a state, without any physical presence.
• Effective tax rate — Tax as a proportion of a defined measure of profit.
• Estate tax treaty relief — Credits and marital mechanisms in an estate tax treaty that reduce a non-resident's exposure, pro-rated by the ratio of situs assets to the worldwide estate.
• Exempt supply — A supply outside the tax with no input tax recovery on its inputs, which is why the exempt-versus-zero-rated distinction is worth money.
• Equalisation levy — An Indian charge on specified digital transactions that sits outside the income tax act, so treaty relief and foreign credit arguments do not work on it in the usual way.
• Economic employer — The entity that in substance bears the cost and directs the work, which can differ from the legal employer and can defeat a treaty exemption.
• Engagement letter — The document setting the scope, the fee and the boundary with any other adviser.
• Evidence pack — The assembled documents supporting a residency, treaty or valuation position, built at the time rather than reconstructed under audit.
• Expat — Everyday shorthand for someone living outside their home country.

What the E entries have in common

19 terms begin with E. 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: Emigrant, Effectively connected income and Economic double taxation.

Nearby letters

D — 17 terms · F — 39 terms. The full A–Z lists all 297 terms in one place.

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