Do I pay US tax on royalties I receive while living in the UK?

Yes. The United States taxes citizens and green card holders on worldwide income, so UK royalty and licensing receipts go on your Form 1040 wherever you live. The UK also taxes them because you are UK resident. The double charge is relieved by a foreign tax credit on Form 1116, not by the zero per cent royalty rate in Article 12, which the saving clause in Article 1(4) of the US-UK convention prevents a US citizen from using against their own US liability.

Are my UK royalties foreign source income for the foreign tax credit?

Not automatically. The IRS summary of source rules at irs.gov states that royalties from patents, copyrights and similar intangibles are sourced by where the property is used, not by the payer's residence or where you live. If a US customer or platform exploits the intellectual property in the United States, that slice is US source and supports no ordinary foreign tax credit. It must instead be re-sourced under Article 24(6)(d) of the treaty on a separate Form 1116.

Should a US citizen in the UK complete Form W-8BEN for a US publisher?

No. The Form W-8BEN instructions state that a US citizen, even one residing outside the United States, must not use the form and should use Form W-9 instead. W-8BEN establishes foreign status so that a payer can reduce the default 30 per cent withholding on US-source income under section 1441. A US person who signs it certifies something untrue, gains nothing because the saving clause preserves US taxation, and creates an information-reporting mismatch that has to be corrected.

Do royalties go on Schedule E or Schedule C, and does self-employment tax apply?

Schedule E Part I is the default for royalties from copyrights, patents, name, image and likeness rights and mineral interests. But the Schedule E instructions say that if you are in business as a self-employed writer, inventor or artist, you report royalty income and expenses on Schedule C instead. Schedule C profit is net earnings from self-employment, so self-employment tax applies once net earnings reach 400 dollars, unless a certificate of coverage under the US-UK social security agreement is filed.

Must my UK company withhold tax when it pays me a royalty?

It depends on the intellectual property and on your residence. HMRC guidance confirms that ITA 2007 section 903 requires a payer of royalties for the use of a patent to deduct basic rate tax, 20 per cent for the 2026 to 2027 tax year, where the payment arises in the UK. The Chapter 7 duty covering copyright, design, trade mark and know-how royalties applies to payments made to a non-UK resident, so the obligation can arise the moment you leave Britain.

US Tax on UK Royalties and Licensing Income

Q: Does licensing my IP to my own UK company trigger Form 5471?

The company itself does. A UK company more than 50 per cent owned by US shareholders is a controlled foreign corporation, and a US person controlling it files Form 5471 as a Category 4 or Category 5 filer. Failure to furnish the information required by section 6038(a) carries a 10,000 dollar penalty per company per year, plus 10,000 dollars for each 30-day period of continued failure up to 50,000 dollars. The royalty is also disclosed as a related-party transaction.

The US tax UK royalties licensing income position for a US citizen or green card holder living in Britain is this: the United States taxes the royalty in full because it taxes its citizens on worldwide income, the United Kingdom taxes the same royalty because you are UK resident, and the double charge is relieved by a foreign tax credit rather than by the treaty withholding rate. The zero per cent royalty rate in Article 12 of the US-UK convention, set out in HMRC's treaty summary at https://www.gov.uk/hmrc-internal-manuals/double-taxation-relief/dt19852, is a withholding rate for foreign persons. It does almost nothing for your own Form 1040. What decides whether the credit actually works is the sourcing rule, and royalty sourcing follows where the intellectual property is used, not where the payer sits and not where the money lands.

That single rule is why royalty cases go wrong in the returns we prepare. A founder in London licensing a software library to US customers, an author whose New York publisher pays into a UK bank account, an investor holding a royalty interest in a patent worked in Texas: all three have US-source income under the Internal Revenue Code, all three are paying UK tax on the same receipts, and none of them can take an ordinary foreign tax credit against that slice without a treaty re-sourcing claim. This guide runs the whole chain, from characterising the payment through to which box it belongs in on Form 1040 and on the Self Assessment return.

US tax UK royalties licensing income: how the two systems interact

A royalty is a payment for the use of, or the right to use, intellectual property. Article 12 of the 2001 UK-USA Double Taxation Convention, published in full at https://www.gov.uk/government/publications/usa-tax-treaties/2001-uk-usa-double-taxation-convention-as-amended-by-the-2002-protocol-in-force, provides that royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other State. The convention entered into force on 31 March 2003, taking effect in the UK from 6 April 2003 for income tax and capital gains tax and from 1 May 2003 for taxes withheld at source. Article 12 also carries three qualifications that matter to founders: paragraph 3 disapplies the exclusive residence-state rule where the beneficial owner has a permanent establishment in the source state, so that Article 7 business profits apply instead; paragraph 4 restricts relief to an arm's length amount where a special relationship exists between payer and beneficial owner; and paragraph 5 removes the Article entirely for any royalty paid under, or as part of, a conduit arrangement.

For a US person living in the UK the work runs in a fixed order, and skipping a step is what produces an amended return two years later.

Characterise the payment: a royalty for the use of intellectual property, a trading receipt of a profession you carry on, or the proceeds of an outright sale of the underlying property.
Source it for US purposes: royalties from patents, copyrights and similar intangibles are sourced by where the property is used.
Report it on the correct US schedule: Schedule E Part I for royalties held as an investment, Schedule C where you are in business as a self-employed writer, inventor or artist.
Claim relief in the right Form 1116 category, and where the royalty is US-source, on a second Form 1116 for income re-sourced by treaty, supported by Form 8833.
Report the same income through UK Self Assessment on the correct pages and claim Foreign Tax Credit Relief only where the United States holds the prior taxing right.

What counts as a royalty, and when a licence is really a sale

Article 12 of the convention defines royalties to include consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, any patent, trade mark, design, model, plan, secret formula or process, and information concerning industrial, commercial or scientific experience. It also reaches gains from the alienation of those rights where the gain is contingent on the productivity, use or disposition of the property. That last limb is the one founders trip over: calling a payment a purchase price does not make it a sale if what you actually receive is a running percentage of exploitation.

On the US side the boundary between a licence and a sale is sharpest for patents. Where a holder transfers all substantial rights to a patent, section 1235 treats the transfer as the sale or exchange of a capital asset held for more than one year, even if the payments are periodic over the transferee's use or contingent on productivity or use. A holder is any individual whose efforts created the property. The trap for a founder is the related-person limitation: the section 1235 treatment does not apply to transfers between persons related under section 267(b), and that includes an individual and a corporation 25 per cent or more in value of which is owned directly or indirectly by that individual. Selling your patent to your own company is therefore precisely the transaction the rule excludes. The IRS discussion of section 1235 and the related-person restriction appears in the National Office technical advice at https://www.irs.gov/pub/irs-wd/0249002.pdf, and the wider sale-or-exchange analysis sits in Publication 544 at https://www.irs.gov/publications/p544.

HMRC works the same divide from the other end. Its Business Income Manual at https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim35725 explains that the fruits of a professional author's brain give rise to revenue receipts to be included in calculating the taxable profits of the profession when they are exploited, because the capital asset is the author's brain rather than the copyright. Expect to defend a capital characterisation on both sides of the Atlantic with the same set of documents, and expect the two revenue authorities to reach different answers on the same contract if the drafting is loose.

The sourcing rule that decides everything: where the intellectual property is used

The IRS summary of source rules, published at https://www.irs.gov/individuals/international-taxpayers/nonresident-aliens-sourcing-of-income and reproduced as Table 2-1 of Publication 519 at https://www.irs.gov/publications/p519, sets the factor determining source for each class of income. For royalties from patents, copyrights and similar intangibles the factor is where the property is used. For royalties from natural resources and for rents the factor is the location of the property. Interest follows the residence of the payer, and the sale of personal property follows the seller's tax home. Royalties are the only major class where the test is an activity carried on by somebody else, which is why the answer so often surprises people.

A foreign tax credit is only available against foreign-source income. So the sourcing conclusion is not a technicality: it decides whether the UK tax you have already paid can shelter the US tax on the same receipts, or whether you face a genuine double charge that has to be unwound through the treaty. In practice a single royalty stream splits.

A UK publisher selling your book to UK readers is using the copyright in the United Kingdom, so the royalty is foreign source for US purposes.
A US streaming platform exploiting your recording for US listeners is using the copyright in the United States, so that slice is US source however the money is routed.
A worldwide licence has to be apportioned by territory of exploitation, and the evidence for the apportionment is the royalty statement and the contract, not a percentage picked after the year end.
The payer's residence, the currency, and the bank account the money reaches are all irrelevant to royalty sourcing.
Where your own company holds the licence, the question is where the company exploits the intellectual property, not where the company is incorporated.

The category matters too. The Form 1116 instructions at https://www.irs.gov/instructions/i1116 list the separate limitation categories as section 951A income, foreign branch income, passive category income, general category income, section 901(j) income and certain income re-sourced by treaty. Passive category income includes dividends, interest, royalties, rents and annuities, but the instructions specifically exclude active business rents and royalties and high-taxed income from that basket. A founder whose royalties arise from an active licensing business is therefore often in the general category, not the passive one, and the high-tax kickout can move income out of the passive basket in its own right where the foreign tax after allocation of expenses exceeds the highest US tax that could be imposed on it. Putting a royalty in the wrong basket is a common cause of a credit that appears on the return but is disallowed on examination.

Article 12 and why the saving clause takes it away from you

Article 1 paragraph 4 of the convention is the saving clause. It allows a Contracting State to tax its residents and citizens as if the convention had not come into effect, subject only to the list of Articles preserved by paragraph 5. Article 12 is not in that list. So a US citizen resident in the UK cannot point at the zero per cent royalty rate and ask the United States to stand down. The zero rate is real, but it is aimed at a UK-resident non-citizen receiving a US-source royalty.

The repair is in Article 24. Paragraph 6(a) says the UK is not bound to give credit for US tax on income from sources outside the United States as determined under UK law. Paragraph 6(b) limits the UK credit to the amount of tax the United States could have imposed on a UK resident who is not a US citizen. Paragraph 6(c) then requires the United States to allow a credit for the UK income tax and capital gains tax paid after that first credit. Paragraph 6(d) completes the circuit: for the exclusive purpose of relieving double taxation in the United States, the income is deemed to arise in the United Kingdom to the extent necessary to avoid double taxation. HMRC's own notes at https://www.gov.uk/hmrc-internal-manuals/double-taxation-relief/dt19853 record the same architecture, confirming that the UK will not provide relief for US tax imposed on its citizens resident in the UK where that tax is charged solely under the saving clause, and that Article 24(6)(c) is what eliminates the resulting double charge.

On the return that means a second Form 1116. The instructions are explicit that you must compute a separate foreign tax credit limitation for any income for which you claim benefits under a treaty, using a separate Form 1116 for each amount of re-sourced income. The treaty position itself is disclosed on Form 8833, described at https://www.irs.gov/forms-pubs/about-form-8833 as the treaty-based return position disclosure required by Internal Revenue Code section 6114. A US-source royalty taxed in the UK, re-sourced under Article 24(6)(d), credited on its own Form 1116 and disclosed on Form 8833 is the correct four-part answer, and it is the part of the file that almost never appears on a self-prepared return.

Do you need Form W-8BEN, or Form W-9?

Form W-8BEN exists because foreign persons are subject to a 30 per cent rate on income they receive from US sources, including royalties, under section 1441. The instructions at https://www.irs.gov/instructions/iw8ben confirm that the form goes to the withholding agent or payer and never to the IRS, that line 9 identifies the treaty country of residence and line 10 carries any special rates and conditions, and that the form remains in effect from the date of signature to the last day of the third succeeding calendar year unless a change in circumstances makes the information incorrect. For a UK-resident non-US author dealing with a US platform, a valid W-8BEN citing Article 12 is what turns 30 per cent into nothing.

It is also the wrong form for most of our clients. The same instructions state that a US citizen, even one residing outside the United States, must not use Form W-8BEN and should instead use Form W-9 to document status as a US person. We see the mistake constantly: a dual national in London signs a W-8BEN for a US publisher or platform, certifies foreign status, obtains a zero rate that the saving clause makes meaningless against their own US liability, and creates an information-reporting mismatch that has to be unwound. Filed correctly on Form W-9, the payer reports on Form 1099-MISC instead. The Schedule E instructions at https://www.irs.gov/instructions/i1040se note that a payer should send a Form 1099-MISC or similar statement where royalties reach 10 dollars or more, and for the 2025 year that statement was due by 31 January 2026.

Form W-8BEN-E, the entity version, does belong in the file where your UK limited company is the licensor receiving US-source royalties, and a plain W-8BEN belongs there for a non-US co-founder or a non-US spouse who owns a share of the rights. Getting the right form to the right payer in the right name is the cheapest part of this whole exercise.

Schedule E or Schedule C, and the self-employment tax that follows

The Schedule E instructions direct you to report on line 4 royalties from oil, gas or mineral properties other than operating interests, copyrights, name, image and likeness rights such as licensing and merchandising agreements, and patents. The critical carve-out follows immediately: if you are in business as a self-employed writer, inventor, artist and so on, you report your royalty income and expenses on Schedule C, not on Schedule E. Publication 525 at https://www.irs.gov/publications/p525 takes the same line. Schedule E royalties not derived in the ordinary course of a trade or business are in most cases not treated as income from a passive activity.

That characterisation is worth real money because Schedule C profit is net earnings from self-employment. The IRS guidance at https://www.irs.gov/individuals/international-taxpayers/self-employment-tax-for-businesses-abroad confirms that the rules for paying self-employment tax are generally the same whether a self-employed US citizen lives in the United States or abroad, that self-employment tax is due where net earnings reach 400 dollars, and that all self-employment income counts even where the gross income was excluded under the foreign earned income exclusion. The exclusion is no help here in any event: the IRS list of what is not foreign earned income, at https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion-what-is-foreign-earned-income, names royalties and rents alongside dividends, interest and capital gains, because earned income means pay for personal services performed.

The fix for a founder or creator already paying UK National Insurance is the social security agreement between the two countries. The same IRS page explains that under these agreements dual coverage and dual contributions for the same work are eliminated, and that to claim exemption from US self-employment tax you request a certificate of coverage from the appropriate agency of the foreign country and attach a photocopy to Form 1040 each year. On the UK side HMRC issues that certificate on application, with the process set out at https://www.gov.uk/guidance/apply-for-a-certificate-to-confirm-you-pay-uk-national-insurance-when-working-in-a-country-that-has-a-social-security-agreement-with-the-uk-ca9107. A creator with Schedule C royalties and no certificate on file is paying self-employment tax on top of Class 2 and Class 4 National Insurance for the same activity.

Royalties paid by your own UK limited company to you personally

This is the structure we are asked about most: the founder keeps the intellectual property personally, the trading company licenses it, and the company pays an annual royalty. It can be perfectly sound. It is also a related-party transaction sitting on a border, and it has to survive four separate tests.

The corporation tax deduction: the royalty must be incurred wholly and exclusively for the purposes of the company's trade, and the licence must actually exist in writing before the payments start.
Transfer pricing: section 166 TIOPA 2010 exempts the vast majority of transactions carried out by small and medium sized enterprises, as HMRC explains at https://www.gov.uk/hmrc-internal-manuals/international-manual/intm412070, but HMRC can issue a transfer pricing notice to a medium sized enterprise and the exemption can be elected out of.
Withholding at source: the duty in ITA 2007 Part 15 has to be considered before every payment, not after the year end.
Characterisation: HMRC will ask whether a payment from your own company to you is genuinely for the use of intellectual property or is really remuneration, and its Employment Income Manual note on image rights royalties at https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim00736 shows how closely the individual circumstances of the arrangement are examined.

On withholding, HMRC's Savings and Investment Manual at https://www.gov.uk/hmrc-internal-manuals/savings-and-investment-manual/saim9130 records that ITA07 section 903 requires the payer of royalties or other sums for the use of a patent to deduct basic rate tax from the payment where it arises in the UK, and that Chapter 7 extends the requirement to other intellectual property payments, mainly copyright and design royalties. The International Manual at https://www.gov.uk/hmrc-internal-manuals/international-manual/intm630310 sets out the section 907 definition of intellectual property after Finance Act 2016, covering copyright of literary, artistic or scientific work, any patent, trade mark, design, model, plan, secret formula or process, information concerning industrial, commercial or scientific experience, and public lending right in respect of a book, and confirms that the Chapter 7 duty bites on payments in those categories made to a non-UK resident. The basic rate is 20 per cent for the tax year running from 6 April 2026 to 5 April 2027, per https://www.gov.uk/income-tax-rates.

The practical consequence is a timing bomb. While you are UK resident, a copyright royalty from your own UK company will usually not engage the Chapter 7 non-resident duty, though the patent rule and the annual payment rules still have to be checked. The moment you leave the UK, the same payment made on the same licence can become a payment to a non-resident, and the company acquires a withholding obligation it has never had before. Company Taxation Manual guidance at https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm35270 confirms that section 911 allows companies to pay royalties overseas deducting only the reduced rate prescribed by the relevant double taxation agreement, but only where the company reasonably believes at the time of payment that the beneficial owner is entitled to that relief, with penalties available where the belief is not sustained. Under the US-UK convention the prescribed royalty rate is nil, but nil by self-assessment still requires the company to hold the evidence.

Do not lose the sourcing point in the mechanics. The company is the user of the intellectual property, so the royalty is sourced by reference to where the company exploits it. A UK company selling a licensed software product predominantly into the United States generates a predominantly US-source royalty in your hands, even though a UK company pays it out of a UK bank account into a UK bank account, and even though HMRC will tax the whole amount as UK income of a UK resident. That is exactly the fact pattern that needs Article 24(6)(d) re-sourcing and a separate Form 1116.

Form 5471 and controlled foreign corporation reporting

If you own or control the UK company, it is almost certainly a controlled foreign corporation. The Form 5471 instructions at https://www.irs.gov/instructions/i5471 define a CFC as a foreign corporation whose US shareholders own, directly, indirectly or constructively, more than 50 per cent of the total combined voting power of all classes of voting stock or more than 50 per cent of the total value of the stock. Category 4 covers a US person who had control of a foreign corporation during the annual accounting period, meaning more than 50 per cent of the combined voting power. Category 5 covers a US shareholder who owned stock in a foreign corporation that was a CFC at any time during the corporation's tax year.

The penalties are why we treat this as the first item on the file rather than the last. A 10,000 dollar penalty applies for each annual accounting period of each foreign corporation for failure to furnish the information required by section 6038(a) within the prescribed time, with an additional 10,000 dollars per foreign corporation for each 30-day period of continued failure, subject to a 50,000 dollar maximum. A founder with three years of unfiled forms for one company is looking at a six-figure exposure before anyone has argued about the royalty rate.

The royalty itself shows up twice on the form. As a deduction it reduces the company's income and its earnings and profits, which changes the figures reported on the income statement and earnings and profits schedules and, in turn, what flows through the subpart F and global intangible low-taxed income computations. As a related-party transaction it is disclosed on the schedule of transactions between the foreign corporation and its shareholders or other related persons that Category 4 filers must complete. Separately, where the UK company is itself the licensor and receives royalties, those receipts can be foreign personal holding company income, which the instructions direct to Schedule I and Worksheet A. Structuring the royalty inside the company rather than personally does not remove the reporting, it moves it.

How the UK side is reported through Self Assessment

GOV.UK guidance at https://www.gov.uk/tax-foreign-income confirms the starting point: if you are UK resident you will normally pay tax on your foreign income, you usually report it in a Self Assessment tax return, and relief may be available where you are taxed in more than one country, sometimes supported by a certificate of residence. The rules that applied before 6 April 2025 to individuals whose permanent home was abroad no longer operate in the same way, so a royalty stream that was previously left off a UK return needs re-examining rather than repeating.

Which pages the royalty belongs on depends on the same characterisation question the US return asks, and the two answers need to agree. Where the royalties are receipts of a profession you carry on, they are trading income and go on the self-employment pages. Where you are not the author or composer, HMRC's manual at https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim50725 states that copyright royalties received by an individual other than the author, unless they form part of the receipts of a trade or represent post-cessation receipts, are chargeable to income tax as miscellaneous income. Where the trade or profession has ceased and the money keeps arriving, the post-cessation receipts rules at https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim50740 take over. Royalties with a foreign source, and any Foreign Tax Credit Relief claim, belong on the foreign pages.

Rates are simply your marginal rates. For the tax year from 6 April 2026 to 5 April 2027 the personal allowance is 12,570 pounds, the basic rate of 20 per cent runs to 50,270 pounds, the higher rate of 40 per cent runs to 125,140 pounds and the additional rate of 45 per cent applies above that, with the personal allowance reduced by 1 pound for every 2 pounds of adjusted net income above 100,000 pounds. A six-figure royalty from your own company will therefore often be taxed at 45 per cent at the margin while also stripping the allowance, which is why the split between salary, dividend and royalty in an owner-managed company deserves a proper calculation rather than a habit.

A worked scenario: a founder licensing software to her own UK company

The following figures are an illustration, not a client case, and any conversion to US dollars on the Form 1040 would use an assumed exchange rate that the return has to document. A US citizen resident in London personally owns the copyright in a software library. She licenses it to her own UK limited company, which she wholly owns, for 120,000 pounds a year under a written licence. The company's sales records show that 70 per cent of the licensed product is exploited with UK and European customers and 30 per cent with US customers.

On the UK side the company claims the 120,000 pounds as a trading deduction, subject to the wholly and exclusively test and to the transfer pricing position, which for a company within the small and medium sized enterprise thresholds is generally covered by the section 166 TIOPA 2010 exemption. She declares the full 120,000 pounds through Self Assessment at her marginal rates for 2026 to 2027, with the personal allowance tapered away. On the US side she reports the same royalty. Because the sourcing test is where the property is used, roughly 84,000 pounds of it is foreign source and roughly 36,000 pounds is US source. The foreign-source slice supports an ordinary foreign tax credit in the correct category on Form 1116. The US-source slice supports no ordinary credit at all, and has to be re-sourced under Article 24(6)(d) onto a separate Form 1116 for income re-sourced by treaty, with the position disclosed on Form 8833. Because she controls a foreign corporation, Form 5471 is due with the return, and the royalty deduction has to be reflected consistently in the company's earnings and profits and in the related-party transaction disclosure. Change one fact, that the company sells only into Britain, and the US-source slice and the second Form 1116 disappear entirely.

The failure modes we see most often

A US citizen signing Form W-8BEN for a US payer instead of Form W-9, certifying foreign status they do not have and gaining nothing because of the saving clause.
Treating every royalty received while living in the UK as foreign source, and claiming a foreign tax credit against a US-source amount that does not support one.
Reporting active licensing royalties in the passive category on Form 1116 when the instructions carve out active business royalties, or missing the high-tax kickout.
Putting a creator's royalties on Schedule E when the activity is a trade, or on Schedule C without a certificate of coverage, so self-employment tax is paid alongside UK National Insurance.
A licence between founder and company that exists only in the accounts, with no signed agreement, no defined territory and no royalty rate that could be evidenced.
Charging a royalty from a UK company for years and never filing Form 5471, then discovering the 10,000 dollar per year penalty structure.
Continuing the same royalty payments after leaving the UK without revisiting the ITA 2007 Part 15 withholding duty on payments to a non-resident.

What a complete royalty file looks like

The signed licence or assignment, showing parties, rights granted, territory, term and the royalty basis.
Royalty statements broken down by territory of exploitation, which is the evidence for the US sourcing split.
Form W-9 given to US payers where you are a US person, or Form W-8BEN and W-8BEN-E for genuinely foreign licensors in the structure.
Form 1040 with Schedule E or Schedule C, Schedule 1 and Schedule SE as characterisation requires.
Form 1116 in the correct category, plus a separate Form 1116 for any income re-sourced by treaty, plus Form 8833.
Form 5471 for any UK company you control, with the royalty reflected in its earnings and profits and related-party disclosures.
The UK Self Assessment return with the royalty on the correct pages, plus the HMRC certificate of coverage where self-employment tax relief is claimed.

Royalty and licensing income is one of the few areas where the two systems can be made to agree almost perfectly, and one of the few where a small drafting decision made when the licence was written determines the tax outcome for a decade. Our cross-border tax preparation work on these files starts with the contract and the royalty statements rather than the tax return, because everything downstream, the sourcing split, the Form 1116 category, the Schedule C question and the Form 5471 disclosures, is decided by those two documents. You can see how we approach that at us-uktax.com/cross-border-tax-planning, and the company-side work at us-uktax.com/business-corporate-tax-planning.