Cross-border tax terms — H

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.

Cross-border vocabulary is mostly a record of disagreement. Two countries look at one arrangement and classify it differently, and the gap between the classifications is where the double tax, or the unintended relief, actually lives. Each page below follows the same shape — definition, consequence, and the specific returns or elections the term reaches.

If this term has turned up in a letter, a slip or an adviser's email and you are not sure which side of it you are on, that is a short call to the helpline rather than a research project. Every page here carries the name of the person who reviewed it and the date they did.

• Hybrid surplus — A surplus pool arising principally from certain capital gains of a foreign affiliate, with its own rules on distribution.
• Hybrid entity — An entity treated as fiscally transparent by one country and as a company by the other.
• Hybrid mismatch — An outcome — a deduction with no inclusion, or a double deduction — arising from two countries classifying an entity or instrument differently.
• Hypothetical tax — The notional home-country tax deducted from an equalised assignee, standing in for what they would have paid had they not moved.

What the H entries have in common

4 terms begin with H. 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: Hybrid surplus, Hybrid entity and Hybrid mismatch.

Nearby letters

G — 10 terms · I — 4 terms. The full A–Z lists all 297 terms in one place.

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