Businesses Expanding Across Borders
Entity structure, state nexus, VAT, payroll, transfer pricing, and treaty positions: the tax architecture for a US/UK expansion, designed and maintained by one team.
Two returns, one plan.
Expanding across the Atlantic means answering to two tax authorities with different rules on entities, payroll, indirect tax, and profit attribution. We design the structure before you launch and run the compliance in both countries after, so growth decisions are never hostage to tax surprises.
From the first sales into the new market to subsidiaries, secondments, and repatriated profits, we handle the annual mechanics and the structural planning together.
How we help expanding businesses
Structure, compliance, and planning for companies operating on both sides of the Atlantic.
UK Companies Entering the US
Entity choice, federal and state registrations, state nexus analysis, sales tax obligations, and US payroll setup, sequenced so your US launch doesn't create liabilities you discover a year later.
US Companies Opening in the UK
UK subsidiary or branch decisions, VAT registration, PAYE setup, and permanent establishment analysis. We build the UK footprint so HMRC obligations are met from the first invoice and the first hire.
Transfer Pricing & Intercompany Agreements
Once related entities sit on both sides of the Atlantic, every intercompany charge needs a defensible arm's-length basis. We design the pricing policy and paper it with proper agreements and documentation.
Treaty-Based Positions
The US/UK treaty can eliminate withholding and protect against taxation without a permanent establishment, if claimed correctly. We prepare Form 8833 disclosures and W-8BEN-E certifications that hold up.
GILTI, CFC & UK Corporation Tax
A US-owned UK company is a CFC, and its profits can flow into US returns through GILTI. We model the interaction with UK corporation tax and structure elections so profits aren't taxed twice at the entity level.
Cross-Border Payroll & Secondments
Sending people across the Atlantic triggers payroll withholding, social security, and residency questions in both countries. We structure secondments and coordinate payroll so employees and employer both stay compliant.
Get your cross-border expansion structured properly before the first filing is due.
Get StartedExplore our tax services
Built for companies operating in two countries.
The most expensive cross-border business problems (accidental permanent establishments, untracked state nexus, undocumented intercompany charges) are all preventable at the design stage. We prevent them there.
Structure is decided once. You pay for it every year.
Entity choice, permanent establishment exposure, and intercompany pricing are set early and compound annually. Companies that treat these as afterthoughts spend years unwinding them. We treat them as the foundation, modeled in both systems before anything is signed.
Entity & Structure Design
Subsidiary, branch, or nothing yet: we model the tax outcomes of each structure in both countries before you register anything.
Permanent Establishment Defense
We design roles, contracts, and operating patterns so your presence in the other country stays on the right side of the treaty line, and we document why.
Intercompany Pricing That Holds
Arm's-length pricing, written intercompany agreements, and documentation that satisfies both the IRS and HMRC, built once and maintained as you grow.
Withholding & Treaty Claims
Form 8833 positions, W-8BEN-E certifications, and treaty rate claims prepared correctly so cross-border payments don't lose money to avoidable withholding.
Why expanding businesses choose US/UK Cross Border Tax
Both Jurisdictions, One Adviser
US CPAs and UK tax advisers work the same engagement, so the entity structure, the intercompany pricing, and both sets of filings are designed as one system.
Structure Before Paperwork
The expensive mistakes happen at setup: the wrong entity, an accidental permanent establishment, nexus nobody tracked. We get the architecture right first.
Ongoing Compliance Cadence
Corporation tax, federal and state returns, VAT, sales tax, and payroll filings run on different calendars. We manage the full cycle so nothing lapses.
Fixed, Transparent Pricing
Cross-border expansion budgets are hard enough to hold. You get a fixed quote up front covering the work in both countries.
"We opened our US arm with advice from separate firms in each country, and the pieces never quite fit. They rebuilt the intercompany agreements, sorted our state registrations, and now the UK and US filings are run as one process. It's the first year-end that hasn't felt like detective work."
Cross-Border Business Tax Questions
Common questions from companies expanding between the US and the UK.
Two Tax Systems, One Team
Email Us
hello@usukcrossbordertax.comLondon Headquarters
4 Crown Place
London EC2A 4BT
United Kingdom
Manchester
CORE
Brown St, Manchester M2 1DH
United Kingdom
San Francisco
600 California St
San Francisco, CA 94108
United States
New York
33 Irving Pl
New York, NY 10003
United States