FAQs
What is the most significant tax risk in UK–US restructuring?
Unexpected exit charges and permanent establishment exposure create the highest risk. These liabilities often arise when planning occurs too late.
Does restructuring always trigger tax?
Restructuring does not always trigger tax, but it frequently creates reporting or valuation obligations that must be managed carefully.
How does the UK–US tax treaty support restructuring?
The treaty reduces double taxation and withholding taxes when the conditions are met and the documentation is correct.
When should a business seek restructuring advice?
Advice should be obtained before legal or operational changes occur to preserve flexibility and reduce exposure.
Can restructuring improve investor confidence?
Yes. Transparent, compliant structures significantly improve due diligence outcomes and valuation confidence.