Cross-border tax terms — I
4 terms beginning with I, each defined at mechanism level.
- 15+Years of the founder's cross-border experience
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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.
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. Every entry closes with the filings it touches, because a definition you cannot attach to a form is not yet useful.
Recognising a term like this in your own paperwork is the useful skill. Working out which side of it you fall on is a short call. Every page here carries the name of the person who reviewed it and the date they did.
- Interquartile range — The middle half of a set of comparable results, commonly used as the acceptable range in a transfer-pricing analysis.
- Implicit support — The benefit a group member gets from mere association with the group.
- Input tax credit — Recovery of tax paid on business inputs.
- Importer of record — The party legally responsible for an import, and therefore the party that can recover the import tax.
What the I entries have in common
4 terms begin with I. 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: Interquartile range, Implicit support and Input tax credit.
Nearby letters
H — 4 terms · J — 2 terms. The full A–Z lists all 297 terms in one place.
Back to the full glossary · Cross-border tax answers · Side-by-side comparisons
Files that look like this one
A range analysis rebuilt after a distributor fell outside it
A distributor had been assessed on the basis that its margin sat below the range in the group's own study, a study prepared years earlier and never revisited. We re-ran the comparable search on current data, examined whether the companies in the original set were really doing what the client does, and documented the commercial events of the years under review. The engagement produced a fresh analysis with a defensible range, a written explanation of the years that genuinely fell outside it and why, and a proposed adjustment the client made themselves rather than having one imposed.
Implicit support argued through on an intercompany loan review
An assessor had priced a loan to a subsidiary as though the borrower stood entirely alone, ignoring its position within a substantial group. The client's original file recorded a rate but not the reasoning behind it. We reconstructed the borrower's credit position on both views, showed how a lender would read its association with the parent, and drew the line short of treating an unwritten expectation as an express undertaking. The engagement produced a documented pricing position, a response to the assessment built on it, and a policy the group now applies whenever it lends internally.
Import tax recovered by naming the right entity on documents
Tax paid at the border was accumulating with a group company that had no ability to recover it, while the company carrying on the business, which could have recovered it, appeared nowhere on the import paperwork. Nobody had chosen this; it followed from who signed the first shipping instruction. We mapped the flow of goods, title and payment, identified who should properly be the importer of record, and put the registrations in place. The engagement produced a corrected import structure, recovery claims for the periods still open, and documentation matching the commercial reality of the transactions.
Input tax credits refused because invoices named the wrong company
Claims had been denied over several periods for a reason unrelated to the underlying expenditure: supplier invoices carried the name of a related company rather than the registered claimant. The expenditure was real, business-related and properly incurred. We reconciled the invoices to the contracts and the payments, established which entity had actually received the supplies, and had documents corrected at source where suppliers would do so. The engagement produced revised claims for the open periods, a written reconciliation supporting them, and an instruction to suppliers that keeps the naming consistent from now on.
A shared service company priced and documented before its first review
A group set up a shared service company and charged its costs to affiliates on a basis the finance team chose without a study behind it. We examined the functions actually performed and the risks actually carried, selected comparable service providers, and tested the mark-up against the range they produced. Where the existing charge sat outside it, the charge was changed going forward rather than defended. The engagement produced contemporaneous documentation for the first year of operation, an intercompany services agreement matching what is really done, and a short annual refresh the group runs itself.
Customs value and transfer price reconciled for one product line
The group declared one value on import and used another for tax purposes on the same goods, each figure arrived at by a different department with no conversation between them. Either could be defended alone; together they invited a question neither team could answer. We traced both to their sources, explained the legitimate reasons the two measures can differ, and documented the reconciliation between them. The engagement produced a single explanatory schedule covering the product line, adjustments where the difference could not be justified, and a process that reviews both figures at the same time each year.
An Adjustment in One Country and No Relief in the Other
A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.
Read how this one runsUS Estate Tax on Assets a Canadian Did Not Know Were Exposed
US shares and US real estate sit inside the US estate tax net regardless of where the owner lives. The treaty provides relief that is proportionate rather than automatic, and the calculation depends on the worldwide estate.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.
Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
