[phillmv]

>You can't just open a new company in another country and expect to start moving your revenue to it, it just doesn't work like that.

It kind of does work like that? Granted, it depends on how you structure it.

I confess I'm not privy to how taxes work in the UK, and that further I'm not an accountant but: I too am responsible for a US and non US corp. You may have to declare your US corp as an asset in the UK, for all I know.

That said, if you have a US legal entity that is booking revenue then HMRC doesn't have any jurisdiction. That USCorp pays US corporate taxes just like any other.

If you move any of the US income to your UKCorp or your UK resident person then the Crown will happily takes its cut.

[chrisdew]

If you are resident in the UK and control a US company, HMRC need to be told about it. https://www.gov.uk/guidance/controlled-foreign-company-an-ov...

The US company will pay 20% UK Corporation Tax on (worldwide) profits and need to fill out CT600 each year.

You will probably be able to pay lower taxes in the US as a result of double taxation treaties, but it's going to be a very tedious task to organise.

[phillmv]

Aha, that's fair. Judging by the site it seems you'll have to take care to demonstrate that you're not shifting UK derived profits; but either way you'll want to chat up an accountant.

In my jurisdiction, to my knowledge and experience, they're considerably more lax.

[wfaler]

Nope, nope, nope.

If it was just about registering a company somewhere else and your home tax authorities had no jurisdiction, every company in the world, small or big would be incorporated in tax havens like the British Virgin Islands only.

If a company is controlled from the UK, you can bet your bottom dollar that the UK tax authorities have jurisdiction. Only a very small minority, mostly less well-developed countries allow you to incorporate elsewhere without having to pay tax and report where you are.

Corporate tax residence internationally tends not to be a matter of where a company is registered, but from where it is effectively controlled. This is a matter of fact, not a matter of paperwork, so you can't get around it by just appointing a buddy to sign papers who lives in the right country.

Not only that, incorporating elsewhere opens a world of complexity, pain and double taxation. A simple example: A US LLC with more than one owner is usually taxed as a partnership - eg, US tax is due at individual marginal rates. The UK on the other hand treats US LLCs as "opaque", which means they'd want to tax it as a corporation (there are legal cases to this fact). So a UK resident LLC owner could end up having to pay up to 39.6% tax in the US, then 20% AGAIN on the very same income in the UK, before having extracted a single cent from the company. Then if they extract money from it, there's an additional up to 38.1% dividend tax, for a whopping 90% marginal tax rate.

Now, double taxation treaties _may_ come to the rescue, but I wouldn't bet on it being without a fight through the courts to prove they apply.

[lstamour]

Yeah, LLCs don't appear to be the best method unless you can prove to the gov't how things were taxed (or not). That said, I'm not entirely sure things get that bad. First off, it's not a 90% rate, by those (worst case) numbers, it's a 70.08% rate. Still absolutely terrible, but... I'd take advantage of any advice you can find, both on local and US perspectives before committing to any course of action involving this product. Particularly looking forward to additional blog posts and resources on this, along with stories of best practices that are country-specific :)