Glossary

Glossary: the key terms explained

International structures come with their own vocabulary. These are the terms that keep appearing in our guides and in conversations with advisors, explained in plain language.

Permanent establishment

A fixed place of business through which a company carries out its activity. If a permanent establishment exists in a country, part of the profit can become taxable there.

Disregarded entity

A US tax classification in which an LLC itself is not taxed. Profits are attributed directly to the owner.

Double taxation treaty

A treaty between two states that governs which country may tax which income and how double taxation is avoided.

ETBUS

Engaged in a US trade or business. If this applies, an LLC can become taxable in the United States.

FBAR

A US report on foreign financial accounts, required once the aggregate value exceeds 10,000 USD in a year.

Form 5472

A US reporting form for certain transactions between an LLC and its foreign owner.

Freezone

A special economic zone in the UAE with its own licensing authority. It differs from the mainland in market access, costs and requirements.

Non-dom

A tax status in some countries under which certain foreign income is treated favourably for newcomers.

Offshore claim

An application in Hong Kong to classify profits as earned outside the territory and therefore exempt from profits tax.

Pass-through

Tax transparency: the entity itself pays no tax, the profit is captured at the level of its owners.

Perpetual traveler

A way of living without a fixed tax residence. Legally possible, in practice demanding in terms of proof and not suitable for everyone.

Entity classification (Rechtstypenvergleich)

The German method of assigning a foreign entity to a domestic legal type. It decides whether an LLC is treated like a corporation or a partnership.

Substance

The provable economic reality of a structure: premises, staff, decisions and costs at the stated location.

Territorial taxation

A system in which only domestically sourced income is taxed. Foreign income remains untaxed under certain conditions.

Exit tax

Taxation of unrealised gains when unlimited tax liability ends, in particular on shares in corporations.

Beneficial owner

The natural person who ultimately controls or benefits from a company. Reportable in a register in many countries.

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