Scaling Overseas

§ QUICK ANSWER

How should a UK startup approach US expansion?

For most UK startups, US expansion follows a staged path: first hire (UK-employed contractor or remote employee in the US), then sales subsidiary (a Delaware LLC or C-Corp owned by the UK parent for sales operations), then potentially a flip (restructuring so the US entity becomes the holding company, often pre-Series B). Each stage has tax implications: transfer pricing rules apply to intercompany services from the first US hire; permanent establishment risk arises when US operations look like a physical presence; the eventual flip ends UK SEIS/EIS access and introduces US tax on the founders. The decision tree depends heavily on whether the long-term centre of gravity is US or UK; getting this wrong leads to expensive restructurings.