Cross-border tax terms — P
22 terms beginning with P, each defined at mechanism level.
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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. Each term page therefore says what the word means, why it bites, and which of our pages it actually changes.
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.
- Part-year resident — Someone resident for only part of a tax year.
- Physical presence test — One of the two US qualifying tests for the exclusion, satisfied by days of presence in a foreign country during a twelve-month period.
- Principal purpose test — An anti-abuse rule denying a treaty benefit where obtaining it was a principal purpose of an arrangement, unless granting it accords with the treaty's object.
- Part XIII tax — Canada's flat withholding on passive payments to non-residents — rent, dividends, interest, pensions, royalties — which a treaty may reduce if the eligibility declaration is on file.
- PFIC — A passive foreign investment company — most commonly a non-US mutual fund or pooled investment.
- Protective return — A return filed to preserve deductions and treaty positions where the filer's conclusion is that no tax is owed.
- Profit split — A method dividing combined profit by reference to the parties' relative contributions, used where both sides make unique and valuable contributions.
- Profit level indicator — The ratio used to measure the tested party's profitability — an operating margin, a return on costs or a return on assets, chosen to fit its functions.
- Permanent establishment — The threshold at which a foreign enterprise's business profits become taxable locally.
- Preparatory or auxiliary — The carve-out that keeps genuinely supporting activity from creating a permanent establishment.
- Profit attribution — The exercise of determining how much profit belongs to a permanent establishment, treating it as if it dealt at arm's length with the rest of the enterprise.
- Place of effective management — The place where key management and commercial decisions are in substance made, which can make a foreign-incorporated company resident in another country.
- Paid-up capital — The tax-recognised capital of a corporation, which determines how much can be returned to shareholders without a deemed distribution.
- Pillar Two — The global minimum tax rules, which compute a group's effective tax rate jurisdiction by jurisdiction from adjusted accounting data no existing return produces.
- Portability — The election allowing a deceased US spouse's unused exemption to be used by the survivor.
- Pipeline planning — A post-mortem strategy addressing the double inclusion that arises when shares are taxed on death and again on distribution, executed inside a defined window.
- Place of supply — The rules deciding which jurisdiction taxes a supply and at what rate.
- Personal services business — A corporation that is in substance an incorporated employee, taxed punitively with most deductions denied.
- PAN — India's permanent account number — the identifier every Indian filing, refund and treaty claim depends on, and the first bottleneck in an NRI file.
- Presumptive taxation — An Indian scheme deeming profit as a percentage of turnover instead of computing it from books, with eligibility conditions and multi-year consequences.
- Published fee — A fee listed on this site for a defined scope, so the number is known before the first call.
- Protective filing — A filing made to preserve a right — a deduction, a treaty position, a refund window — where the conclusion is that no tax is owed.
What the P entries have in common
22 terms begin with P. 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: Part-year resident, Physical presence test and Principal purpose test.
Nearby letters
O — 4 terms · Q — 3 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
Cross-border situations we are engaged for
PFIC classification reviewed before a client's foreign fund purchase
A client was about to invest in a foreign mutual fund and had not considered whether it would be classified as a PFIC, which carries its own punitive default tax treatment for a US filer unless an election is made. We reviewed the fund's structure against the PFIC tests, confirmed the classification applied, and prepared the election that gave the client a more favourable ongoing tax treatment than the default rules would have produced.
Permanent establishment analysis prevented an unnecessary Part XIII withholding
A foreign company's Canadian activity had been assumed by its own finance team to fall outside permanent establishment, and a Canadian payer had begun applying Part XIII withholding to payments to it on a cautious assumption instead. We reviewed the activity against the applicable treaty test, confirmed no permanent establishment existed, and the withholding was corrected to the treaty-appropriate treatment rather than the cautious default.
Protective return filed to preserve a client's position pending a residency dispute
A client's residency status for a departure year was under dispute with two possible outcomes, and filing on either assumption risked being wrong once the dispute resolved. We filed a protective return preserving the client's position under both possible outcomes, so that whichever way the residency question was ultimately decided, the client's filing history remained complete and defensible.
Presumptive taxation compared against actual computation for a small cross-border business
A client operating a small business with a presence in more than one country was using a presumptive-style computation in one jurisdiction without having compared it against what an accurate computation of actual expenses would show. We modelled both approaches, found the presumptive method was costing more tax than the business's real margins justified, and moved the client to accurate computation for that jurisdiction going forward.
A Relief That Turned on Days Nobody Had Recorded
Treaty exemption, residence and social security are each decided by a count that has to be evidenced rather than recalled. The engagement builds the record from tickets, rosters and payroll before applying any article.
Read how this one runsCanadian Pension Paid Abroad and Taxed at the Flat Rate
Pension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.
Read how this one runsThree Countries in One File and Two Treaties That Disagree
Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.
Read how this one runsA Secondment Whose Paperwork Decided the Tax
Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.
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
- 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
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- 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



