US and UK Tax Accountants in the UK: Dual Taxation Guide

Understanding Dual Taxation for Creators

If you’re a digital creator or influencer earning from both the United States and the United Kingdom, navigating taxes can feel overwhelming. The inquiry, “Will I pay taxes twice?” is one of the biggest concerns for expats and online entrepreneurs. That’s where US and UK tax accountants in the UK step in — helping you understand, manage, and minimise your tax obligations under both systems.

Whether you’re a US citizen living in the UK or a British creator earning from American platforms, this guide breaks down everything you need to know about dual taxation, tax treaties, and innovative ways to stay compliant.

Why Dual Taxation Matters for Creators

Creators now earn across borders — YouTube ad revenue from the US, brand deals from the UK, and sponsorships from global agencies. While that’s exciting, it brings tax complexity.

Here’s what typically happens:

• The US Internal Revenue Service (IRS) taxes US citizens on worldwide income.

• The UK’s HMRC taxes income earned in the UK (and often from global sources if you’re a resident).

Without proper tax planning, you could pay tax twice on the same income — once to each country. But with the help of Expat Tax Accountants UK, you can legally avoid double taxation and ensure every deduction counts.

The Role of US and UK Tax Accountants in the UK

Working with professional US and UK tax accountants ensures your finances remain compliant, efficient, and stress-free. These experts specialise in both tax systems and handle everything from filings to treaty claims.

Here’s what they help with:

1. Tax Residency Status
   They determine where you’re legally “tax resident.” This affects which country has primary tax rights over your income.

2. Tax Treaty Application
   The US–UK Tax Treaty prevents double taxation on the same income. Accountants help you apply credits or exemptions correctly.

3. Foreign Tax Credits
   If you pay tax in one country, you can often claim credits in the other to offset what you owe.

4. Self-Employment and Platform Income
   Whether you earn via YouTube, Patreon, TikTok, or affiliate links, accountants ensure your income is reported correctly on both returns.

5. FATCA and FBAR Compliance
   US citizens must report foreign bank accounts and assets. Experienced Expat Tax Accountants in the UK help you stay compliant with US reporting laws while managing your UK tax filings.

Common Tax Scenarios for US–UK Creators

If you’re unsure where to start, here are three typical creator scenarios — and how an accountant helps.

Scenario 1: US Citizen Living in the UK

You live full-time in London but earn income from US-based platforms like YouTube and Patreon.

• The IRS taxes you on global income.

• HMRC taxes you as a UK resident.
  Your accountant uses the Foreign Earned Income Exclusion (FEIE) or Foreign Tax Credit (FTC) to reduce or eliminate double taxation.

Scenario 2: UK Creator Paid by US Companies

You’re a British influencer collaborating with US brands. The IRS may withhold a portion of your income for US taxes.

• Your accountant ensures that the tax withheld in the US is credited against UK taxes owed.

• They assist you in completing W-8BEN forms, helping to prevent unnecessary withholding.

Scenario 3: Dual Citizen or Frequent Traveller

You split time between both countries. In this case, your tax residency status becomes crucial. Accountants analyse your ties, home, and stay length to determine the correct tax obligations.

How to Avoid Double Taxation as a Creator

Avoiding double taxation requires proactive management. Here’s what you should do:

1. Work with a Cross-Border Specialist
   Not every accountant understands dual taxation. Select US and UK tax accountants in the UK who possess international expertise, such as JungleTax.

2. Keep Detailed Records
   Maintain income records, invoices, and tax documents from both countries. Consistency helps prevent discrepancies.

3. Claim Treaty Reliefs
   The US–UK tax treaty outlines where specific income types (e.g., self-employed, royalties) are taxed. Applying these rules correctly avoids duplication.

4. Use Tax Software Wisely
   If you file yourself, tools like TurboTax or TaxSlayer may not handle international returns correctly. A professional ensures compliance and accuracy.

5. Understand Filing Deadlines
   
   • US Tax Deadline: 15 April (automatic 2-month extension for expats)

   • UK Tax Deadline: 31 January (following the tax year ending 5 April)

Missing deadlines can result in penalties in both countries.

Why Creators Choose JungleTax

At JungleTax, we help US expats, UK creators, and international influencers navigate complex tax situations with ease. Our specialist US and UK tax accountants in the UK combine global expertise with practical solutions tailored to creators.

We assist with:

• Dual tax filings (US and UK returns)

• Tax treaty and credit applications

• FATCA/FBAR compliance

• Self-employed creator income management

• Cross-border bookkeeping and consultancy

Our mission? To help you save money, stay compliant, and focus on creating — not calculating.

Key Tax Reliefs for Dual Taxpayers

Here are key tax reliefs that creators should know about:

• Foreign Earned Income Exclusion (FEIE): Allows US citizens abroad to exclude up to $120,000 (2025 limit) of foreign income from US taxes.

• Foreign Tax Credit (FTC): Offsets US tax with taxes paid in the UK.

• Tax Treaty Articles 7 & 14: Specifies which country can tax self-employment and royalties.

• Double Taxation Relief (UK): Reduces UK tax liability if you’ve already paid the US IRS.

Understanding these ensures you never pay more than required.

Mistakes to Avoid in Dual Tax Filing

Even experienced creators make errors that cost them money or trigger audits. Avoid these:

1. Not declaring global income is not an option, as both HMRC and IRS require full disclosure.

2. Missing foreign account reports (FBAR) can result in fines of up to $10,000 per account.

3. Failing to claim tax credits properly leads to double payments.

4. Using accountants without cross-border experience — local-only firms often overlook treaty benefits.

By partnering with Expat Tax Accountants UK, you avoid costly mistakes and keep your creative business thriving.

Summary

Dual taxation doesn’t have to be daunting. With the help of US and UK tax accountants in the UK, you can simplify complex cross-border rules, claim valuable credits, and ensure you only pay what’s required.

Creators like you deserve expert tax support that understands both your art and your income streams. Let JungleTax handle the numbers so you can focus on creating.

Call to Action

For expert help with your taxes, contact JungleTax today at hello@jungletax.co.uk or call 0333 880 7974.