Cross-border tax terms — Z
1 term beginning with Z, 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.
Most of these terms exist because two tax systems describe the same thing differently, or because one system has a concept the other does not. That is where cross-border files go wrong quietly: a position that is obviously right at home has no counterpart abroad, and the mismatch — rather than the rate — becomes the exposure. Each term page therefore says what the word means, why it bites, and which of our pages it actually changes.
Most people arrive at a term like this because something arrived in the post. If that is you, the fastest route is to describe the document rather than research the concept. Every page here carries the name of the person who reviewed it and the date they did.
- Zero-rated supply — A taxable supply charged at nil, which preserves input tax recovery — unlike an exempt supply, which does not.
Only one term begins with this letter. Its own page carries the full treatment; use the A–Z above for anything else.
Zero-rated supply
A taxable supply charged at nil, which preserves input tax recovery — unlike an exempt supply, which does not. Follow the entry itself for the mechanism, the filings it decides, and the fixed fee attached to that work.
Nearby letters
W — 7 terms · 0-9 — 1 term. The full A–Z lists all 297 terms in one place.
Back to the full glossary · Cross-border tax answers · Side-by-side comparisons
What these engagements turn on
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 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 runsCanadian Dividends and Interest Paid to a Non-Resident
Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.
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 runsFifteen Per Cent Held Back From a Fee for Services in Canada
A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.
Read how this one runsResidency Changed Mid-Year and Both Returns Assumed a Full One
A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.
Read how this one runsSocial Security Contributions Owed in Two Countries at Once
A totalization agreement assigns contributions to one system and exempts the other, but only against a certificate obtained in advance. Without it both sets come out of the same salary and neither is straightforward to recover.
Read how this one runsUnreported Foreign Income Disclosed Before the CRA Asked
A voluntary disclosure has to be genuinely voluntary — once a letter arrives, the route usually closes. The engagement establishes whether the programme is still available, prepares the years, and puts the relief request in with the filing rather than after it.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
Non-Resident Canadian Tax
Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
Performance income is taxed where earned — Regulation 105 in Canada, withholding agreements in the U.S. — with special treaty articles overriding the usual rules.
Performance income is taxed where the performance happens, and the deduction is usually taken at source on the gross fee before expenses. Recovering the difference is a filing exercise in the other country, and it only works if the tour, the residency and the withholding certificates were documented while the work was being done.
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
