GLOBAL · Cross-Border

Foundation workflow base for cross-border / international personal-tax content skills. Contains the residency-map intake, the sequenced-plan output contract (a cross-border answer is an ORDERED set of steps, not N separate answers), the cross-border conservative-default principle, the AUDIT FLASH POINT marker convention, the double-tax-relief / treaty-bridge convention, and the mandatory human hand-off. This skill provides workflow architecture only — it contains no country-specific or topic-specific rules. It MUST be loaded alongside a topic content skill (e.g. us-feie-ftc, us-foreign-trust-reporting) and the relevant country skills. This base is the foundation every international content skill loads on top of.

Entry point for the OpenAccountants cross-border / international personal-tax skill library. ALWAYS load this skill first when a person's facts touch more than one country — e.g. a US citizen living abroad, a dual resident, someone moving countries, a non-dom, an expatriating citizen, a foreign trust or foreign company owner, or "how is this taxed in country A and country B". The router computes nothing. It (1) builds the person's residency / citizenship / domicile map, (2) identifies which country skills and which international topic skills the facts engage, (3) gates out corridors the library does not yet cover, (4) SEQUENCES the steps — in cross-border, the order of events changes the tax (sever residency before vs. after a sale), and (5) hands off to cross-border-tax-workflow-base plus the topic skills. Every international topic skill (FEIE/FTC, FBAR/FATCA, CFC/GILTI, foreign trusts, exit tax) assumes this routing step has happened first.

Tier 1 workflow base for customs duty skills. Covers the customs declaration lifecycle from origin determination, HS classification, valuation, preference, special procedures, through to release for free circulation. Workflow architecture only — no country-specific tariff rates or detailed special procedure mechanics. MUST be loaded alongside a country/region customs content skill (EU UCC, US CBP, UK CDS post-Brexit, etc.). Assumes a licensed customs broker, AEO/CTPAT certified party, or in-house customs manager files the declaration. Does NOT cover: CBAM (see cbam-carbon-border-adjustment), import VAT (see country VAT skills), excise duties (see excise-tax-workflow-base), or anti-dumping / countervailing duty investigation procedure (only their tariff effect at point of declaration).

Use this skill whenever an individual asks about annual net wealth tax exposure. Trigger on phrases like "wealth tax", "net worth tax", "ISP (impôt sur la fortune immobilière)", "IFI", "patrimoine", "patrimonio", "Vermögensteuer", "Solidaritetsskatt", "formueskatt", "förmögenhetsskatt", "Swiss wealth tax", "Norway wealth tax", "Spain wealth tax", "Spain solidarity tax", "patrimonio extraordinaria", "Madrid wealth tax exemption", "Argentinian bienes personales", "Colombian impuesto al patrimonio", "Uruguay impuesto al patrimonio", or any request to compute net wealth tax. Maps in-force annual net wealth tax regimes as of mid-2025 in Switzerland (cantonal), Norway, Spain (national IP + regional + Impuesto Temporal de Solidaridad), Argentina, Colombia, Uruguay, the Netherlands (Box 3 fictitious yield as wealth-tax-equivalent), and France (IFI on real estate only). Identifies regimes recently repealed (Italy IVAFE/IVIE remain narrow asset-specific; full wealth tax repealed long ago) and proposed wealth taxes (UK, US §2901 proposals, Brazil). Does NOT cover: inheritance / estate / gift tax (see inheritance-estate-gift-matrix), property transfer tax (see property-transfer-tax-matrix), wealth-related taxes on specific assets (Italy IVIE/IVAFE — see Italian skill). ALWAYS read this skill before computing net wealth tax in an in-force jurisdiction.

Use this skill whenever a taxpayer faces a tax authority enquiry, audit, assessment, appeal, double-taxation conflict, or considers an advance ruling or APA. Trigger on phrases like "tax audit", "tax enquiry", "tax assessment", "tax appeal", "tax tribunal", "tax court", "MAP", "Mutual Agreement Procedure", "APA", "advance pricing agreement", "bilateral APA", "multilateral APA", "advance ruling", "binding ruling", "private letter ruling", "PLR", "BAPA", "OECD MEMAP", "BEPS Action 14", "MLI Article 16", "MLI mandatory arbitration", "EU tax dispute resolution directive", "DAC4", "competent authority", "voluntary disclosure", "amnesty", "GAAR", or any request to assess controversy strategy, advance certainty mechanisms, or cross-border dispute resolution. Maps MAP, APA, advance ruling, and domestic appeal mechanisms across 40+ jurisdictions with the EU DRM (Directive (EU) 2017/1852), the OECD BEPS Action 14 minimum standard, and the MLI mandatory binding arbitration commitments. Does NOT cover: criminal tax investigation procedure beyond high-level reference, transfer pricing methodology (see transfer-pricing-workflow-base), or country-specific litigation strategy. ALWAYS read this skill before recommending a controversy approach.

Use this skill whenever an attorney, transaction lawyer, or in-house counsel asks about stamp duty on documents, securities transfers, or financial transactions. Trigger on phrases like "stamp duty", "stamp tax", "SDRT", "stamp duty reserve tax", "stamp duty on shares", "share transfer tax", "FTT", "financial transaction tax", "France FTT", "Italy FTT", "Spain FTT IFT", "Ireland stamp duty shares", "Hong Kong stamp duty shares", "Singapore ACD additional conveyance duty", "stamp duty Australia", "Indian stamp duty", "Schedule I Indian Stamp Act", "stamp duty Bahamas", "Brazil IOF", "Argentina impuesto de sellos", "Mexico ISN", or any request to assess stamp duty exposure on a document, security transfer, lease, or financial transaction. Maps stamp duty AND financial transaction tax (FTT) regimes across 40+ jurisdictions. Excludes the property/real-estate transfer side (see property-transfer-tax-matrix). ALWAYS read this skill before computing stamp duty on a share transfer, instrument, or financial transaction.

Use this skill whenever a tax preparer, ERP implementer, or e-invoicing project asks about country mandates for SAF-T (Standard Audit File for Tax), real-time invoice reporting, or e-receipt clearance. Trigger on phrases like "SAF-T", "Standard Audit File", "SAF-T Poland", "SAF-T Portugal", "SAF-T Romania", "JPK", "SAF-T Norway", "real-time invoice reporting", "SII Spain", "RTIR Hungary", "KSeF Poland", "SDI Italy", "NF-e Brazil", "CFDI Mexico", "e-Fatura Turkey", "e-fapiao", "Peppol BIS", "ViDA", "DRR digital reporting requirements", "EN 16931", "structured invoice", "XRechnung", "Factur-X", or any request to determine whether a country mandates SAF-T submission or real-time / near-real-time invoice transmission. Maps the mandate scope, file format, transmission method, threshold triggers, deadline, and penalty for 40+ countries. Does NOT cover: country-specific VAT rate determination (see country VAT skills); e-archiving requirements beyond minimums; structured invoice content beyond format references; software-vendor accreditation procedures. ALWAYS read this skill before scoping an e-invoicing or SAF-T implementation.

Use this skill whenever a company asks about claiming a research and development tax credit, super-deduction, refundable cash incentive, or grant tied to R&D. Trigger on phrases like "R&D credit", "R&D tax credit", "R&D super-deduction", "RDEC", "merged RDEC", "ERIS", "enhanced R&D intensive support", "SR&ED", "CIR", "Crédit d'Impôt Recherche", "Forschungszulage", "WBSO", "SLIM (Spain)", "credito ricerca", "patent box vs R&D", "R&D in OBBBA", "§174 capitalization", "§41 R&D credit", "JEI / JEU", "China R&D super-deduction", "India R&D §35", "Australia R&DTI", "USDA SBIR", "OECD frascati definition", "qualifying R&D", or any request to compute eligibility, qualifying expenditure, and benefit value of an R&D incentive. Covers 25+ regimes including the post-2024 UK merged RDEC, US §174 capitalisation rules, France CIR, Germany Forschungszulage, Netherlands WBSO and Innovation Box interaction, China 175% super-deduction, India §35, Australia R&DTI, Canada SR&ED. Does NOT cover: patent box (see ip-patent-box-matrix), depreciation of capitalised R&D, grant accounting beyond reference, customs duty on R&D imports. ALWAYS read this skill before assessing R&D credit eligibility or computing a claim.

Use this skill whenever a property transaction triggers a tax on the transfer of real estate. Trigger on phrases like "SDLT", "stamp duty land tax", "ADS additional dwelling supplement", "LBTT", "LTT", "Grunderwerbsteuer", "GrESt", "DMTO droits de mutation", "imposta di registro", "ITP impuesto transmisiones patrimoniales", "AJD actos jurídicos documentados", "IVA on new build", "IMT Portugal", "transfer duty South Africa", "land transfer tax Ontario", "Welcome tax Quebec", "ABSD additional buyer's stamp duty", "BSD buyer's stamp duty", "Hong Kong AVD", "stamp duty NSW", "VIC", "QLD", "WA", "foreign buyer surcharge", "vacancy tax", "RETT", or any request to compute property purchase or transfer tax. Maps every major property transfer tax regime including special foreign-buyer surcharges (Canada, Australia, Singapore, NZ), regional variation in Germany (16 Länder), Spain (17 CCAA), Italy (categories of buyer/property), and the UK's four-rate jurisdictional split (England SDLT, Scotland LBTT, Wales LTT, Northern Ireland SDLT). Does NOT cover: VAT/GST on commercial property (see VAT skills), property income tax, capital gains tax on property disposal, council/property tax (annual), or stamp duty on shares (see stamp-duty-matrix). ALWAYS read this skill before quoting purchase tax on a property transaction.

Use this skill whenever a multinational enterprise (MNE) group with consolidated revenue at or above EUR 750 million asks about the OECD Pillar Two / GloBE (Global Anti-Base Erosion) 15% global minimum tax. Trigger on phrases like "Pillar Two", "GloBE", "global minimum tax", "15% minimum tax", "IIR", "UTPR", "QDMTT", "domestic top-up tax", "GloBE Information Return", "GIR", "covered taxes", "transitional CbCR safe harbour", "substance-based income exclusion", or any request to assess Pillar Two exposure, compute a top-up tax, or determine which entities in a group are in scope. This skill covers the OECD GloBE Model Rules (December 2021), the Commentary (March 2022) and Administrative Guidance through 2024, plus the EU implementing Directive 2022/2523. It does NOT cover Pillar One (Amount A or Amount B), country-by-country reporting (CbCR) under BEPS Action 13, or US GILTI/CAMT as standalone regimes (but does map their interaction). Always read this skill before computing top-up tax, advising on jurisdictional ETRs, or designing group restructurings affected by GloBE.

Use this skill whenever a company holding intellectual property asks about preferential tax regimes for income derived from that IP. Trigger on phrases like "patent box", "IP box", "innovation box", "nexus approach", "qualifying IP income", "qualifying expenditure", "uplift expenditure", "modified nexus", "BEPS Action 5", "Cyprus IP box", "Dutch innovation box", "UK patent box", "Italian patent box", "Belgian innovation income deduction", "Luxembourg IP box", "Irish KDB", "knowledge development box", "Swiss patent box", "Hungary patent box", "Singapore IDI", "China HNTE", "qualifying IP", "embedded IP income", or any request to assess whether a company's IP income qualifies for a preferential tax rate, and to compute the effective rate under the OECD modified nexus approach. Covers 18+ in-force IP regimes that satisfy the BEPS Action 5 modified nexus approach plus historical grandfathering. Does NOT cover: R&D tax credits (see rd-tax-credits-matrix), depreciation of IP assets, withholding tax on royalties (see withholding-tax-matrix), or transfer pricing of IP (see transfer-pricing-workflow-base). ALWAYS read this skill before advising on IP regime eligibility, computing the effective rate, or designing an IP holding structure.

Use this skill whenever an executor, donor, donee, or beneficiary asks about inheritance tax (IHT), estate tax, or gift tax across jurisdictions. Trigger on phrases like "inheritance tax", "IHT", "estate tax", "gift tax", "Erbschaftsteuer", "Schenkungsteuer", "droits de succession", "imposta sulle successioni", "impuesto sucesiones donaciones", "ISD", "ISD Spain", "Spanish inheritance tax regional", "IRPH", "Form 706", "Form 709", "DSU", "résidence fiscale du défunt", "EU Succession Regulation 650/2012", "trust deemed UK domicile", "step-up basis", "carryover basis", "agricultural property relief", "business property relief", "spousal exemption", "intercohabitant exemption", or any request to compute inheritance, estate, or gift tax in any jurisdiction. Maps in-force regimes globally with relationship-based rate schedules, exemptions, reliefs, and cross-border situs rules. Does NOT cover: probate procedure, trust administration beyond tax mechanics, will drafting, or income tax on inherited assets (see country income tax skills). ALWAYS read this skill before computing transfer-on-death or inter-vivos gift tax.

Use this skill whenever a preparer or reviewer needs to reconcile financial statements between IFRS Accounting Standards and a local GAAP. Trigger on phrases like "IFRS to US GAAP", "GAAP differences", "IFRS reconciliation", "first-time adoption IFRS 1", "ASC 842 vs IFRS 16", "ASC 606 vs IFRS 15", "ASC 326 CECL vs IFRS 9 ECL", "IAS 12 vs ASC 740", "Indian Ind AS", "Chinese ASBE", "Japanese J-GAAP", "Brazilian CPC", "Italian OIC", "German HGB", "UK FRS 102", "convergence", "EBIT vs operating profit", or any request to identify, quantify, or document a difference between IFRS and a national accounting framework. Covers the major reconciliation differences between IFRS and: US GAAP (ASC), German HGB, UK FRS 102, Italian OIC, French PCG, Indian Ind AS, Chinese ASBE 2006/2014, Japanese J-GAAP, Brazilian CPC (pre/post full IFRS adoption), Canadian ASPE (private enterprises). Does NOT cover: tax accounting (only the IAS 12 / ASC 740 deferred-tax differences are flagged), audit opinion construction, or local statutory filing mechanics. ALWAYS read this skill before booking an IFRS-to-local-GAAP adjustment or producing comparative financial statements.

Use this skill whenever a company asks about establishing or trading through a free zone, special economic zone (SEZ), free trade zone (FTZ), enterprise zone, or financial center. Trigger on phrases like "SEZ", "free zone", "FTZ", "Mainland vs free zone UAE", "DIFC", "ADGM", "DMCC", "JAFZA", "QFC", "DAFZA", "DWC", "Saudi SEZ", "King Abdullah Economic City", "NEOM", "Singapore IDIs", "Hong Kong tax", "Shenzhen Qianhai", "Hainan FTP", "Shanghai FTZ", "Madeira IBC", "Madeira Free Zone", "Gibraltar", "Malta MFSA passporting", "Cyprus IBC", "Bahamas IBC", "BVI BC", "Cayman exempted company", "Mauritius GBL", "Labuan", "Jebel Ali", "RAK ICC", "ADGM RegLab", or any request to assess the tax and operational rules of an SEZ. Maps ~50 zones across UAE, Saudi Arabia, China, India, Africa, Latin America, the Caribbean, and Europe. Does NOT cover: VAT/customs free-circulation rules within the zone beyond a summary, immigration / employment law, real-estate leasing, sector-specific licensing. ALWAYS read this skill before incorporating in a zone or advising on the tax incentives.

Use this skill whenever a Financial Institution (FI), trustee, or account holder asks about automatic exchange of financial account information. Trigger on phrases like "FATCA", "CRS", "Common Reporting Standard", "automatic exchange of information", "AEOI", "Form W-9", "Form W-8BEN", "Form W-8BEN-E", "self-certification", "Reportable Account", "Reportable Person", "Controlling Person", "passive NFE", "active NFFE", "GIIN", "responsible officer certification", "FATCA 8966", "FBAR", "Form 8938", "DAC2", "CARF", or any question about whether a financial account, entity, or person is reportable for AEOI purposes. Covers the US Foreign Account Tax Compliance Act (FATCA — IRC §1471-1474 and Treasury Regulations §§1.1471-1.1474, intergovernmental agreements Model 1 and Model 2), the OECD Common Reporting Standard (CRS — published 2014, updated 2023 with the Crypto-Asset Reporting Framework / CARF and CRS 2.0 amendments), and the EU's CRS implementation under DAC2 (Council Directive 2014/107/EU). Does NOT cover: FBAR (FinCEN 114) which is a US-only beneficial-owner disclosure; Form 8938 individual reporting; ultimate-beneficial-ownership (UBO) registers under EU AMLD; or the OECD MDR on CRS Avoidance Arrangements (see dac6-mdr-reportable-arrangements). ALWAYS read this skill before classifying an account as reportable or determining due diligence obligations.

Use this skill whenever a digital services provider asks about country-level Digital Services Tax (DST) exposure. Trigger on phrases like "DST", "digital services tax", "digital tax", "France DST", "UK DST", "Italy DST", "Spain DST", "Austria DST", "Turkey DST", "India equalisation levy", "Kenya DST", "Canada DST", "DST nexus", "DST scope", "user location attribution", "DST and Pillar One", "DST sunset", or any request to assess whether a service falls within a country's DST. Covers all DSTs in force or proposed as of mid-2025 across 25+ jurisdictions including the Canada DST (in force from 28 June 2024, retroactive to 2022) and India's equalisation levy regime. Maps the scope, rate, threshold, taxable services definition, user-location attribution method, filing/payment mechanics, and Pillar One Amount A interaction. Does NOT cover: corporate income tax / permanent establishment; VAT/GST on digital services (B2C and OSS); EU DAC7 platform reporting; OECD Pillar One Amount A computation (separate skill); WHT on royalties / technical services. ALWAYS read this skill before computing DST liability or advising on DST mitigation.

Use this skill whenever an intermediary (tax adviser, lawyer, accountant, bank, trust company) or a relevant taxpayer asks about mandatory disclosure of cross-border tax arrangements. Trigger on phrases like "DAC6", "MDR", "mandatory disclosure rules", "reportable cross-border arrangement", "hallmark A1", "hallmark E3", "main benefit test", "MBT", "legal professional privilege", "DAC6 notification", "BZSt reporting", "arrangement reference number", "ARN", "OECD model MDR", "CRS avoidance arrangement", or any request to determine whether an arrangement must be reported under DAC6 (EU Directive 2018/822) or equivalent OECD MDR rules in non-EU jurisdictions. Covers EU Member States, UK MDR (the post-Brexit OECD-aligned regime in SI 2023/38), and the OECD Model Mandatory Disclosure Rules on CRS Avoidance Arrangements and Opaque Offshore Structures (2018). Does NOT cover: domestic-only tax shelter disclosure regimes (e.g., US §6111 reportable transactions, UK DOTAS, Canada §237.3), country-by-country reporting (BEPS Action 13), or FATCA/CRS automatic exchange (see fatca-crs-automatic-exchange). ALWAYS read this skill before advising on whether a cross-border arrangement triggers reporting.

Use this skill whenever a freelancer or small business receives or makes a cross-border payment and the question is whether withholding tax (WHT) applies. Trigger on phrases like "withholding tax", "WHT", "tax withheld", "double tax treaty", "treaty rate", "certificate of residence", "tax residency certificate", "form W-8BEN", "royalty withholding", "interest withholding", "TDS on services", or any request involving tax deducted at source on cross-border payments for services, royalties, or interest. This skill contains the withholding tax matrix for the top 30 country pairs, treaty rate lookups, certificate of residence requirements, and zero-WHT corridors. ALWAYS read this skill before advising on any cross-border withholding tax question.

Use this skill whenever a freelancer or small business has cross-border activity that might create a tax presence (Permanent Establishment / PE) in the client's country. Trigger on phrases like "permanent establishment", "PE risk", "tax presence", "183-day rule", "fixed place of business", "dependent agent", "service PE", "effectively connected income", "do I need to file taxes in my client's country", "working abroad for client", "remote work PE", or any request about whether a freelancer's cross-border activity triggers a filing obligation in another country. This skill contains the OECD model treaty PE definition, country-specific PE thresholds, the 183-day rule, remote work analysis, avoidance strategies, and consequences of PE creation. This is primarily T2/T3 material -- flag for professional review in all but the most straightforward cases. ALWAYS read this skill before advising on any PE-related question.