International expansion & US subsidiary support

Expanding a UK startup overseas, subsidiaries, permanent establishment risk, transfer pricing and the US flip question, answered before you commit.

• Structure options: branch, subsidiary, holding company or flip

• Permanent establishment risk assessed against your actual activity

• Intercompany agreements and a proportionate transfer pricing basis

• Overseas payroll and employer-of-record options compared

• VAT and sales tax registration obligations mapped

• Coordination with local advisers in the destination country

A permanent establishment can be created by a fixed place of business or by a person habitually concluding contracts in another country. Once created, part of your profit is taxable there, and a senior salesperson hired abroad is the most common unintentional trigger.

Intragroup transactions must be priced on arm's-length terms. Smaller UK groups may fall within the SME transfer pricing exemption, but the exemption is not universal and does not remove the need for sensible intercompany documentation.

A US 'flip', inserting a Delaware parent above the UK company, can end SEIS/EIS relief for existing investors and disqualify an EMI scheme if not handled with care and, where relevant, HMRC clearance. It is reversible only at cost, so model it before signing anything.

Thresholds, rates and deadlines quoted here reflect the 2026/27 UK position. Check current GOV.UK guidance, or ask us, before you rely on them for your own company.

We start by looking at the last filed accounts, your current records and your filing dates, then confirm a fixed scope and fee in writing.

Once the work is live you get reminders ahead of each deadline, a named person to ask questions, and a plain-English summary when the figures are ready, not a PDF with no explanation.