Navigating the journey of relocating back to the UK 

How do you leave the United States and renounce your green card without triggering the US exit tax? That was the challenge posed to our cross-border teams in the US and the UK. 

The clients – a couple holding US green cards and running a profitable US software consulting business – were looking to relocate back to the UK and restructure their business operations accordingly. Their primary concerns revolved around minimising tax implications and establishing a tax-efficient structure for their new UK business.

Laying the foundations 

Our US team conducted a thorough business valuation for expatriation purposes, collaborating closely with our UK team to determine the optimal timing for the change in tax residency. 

In parallel, our transfer pricing specialists ensured a precise and tax-efficient allocation of profits between the US and UK, strategically setting the groundwork for the future operations of the business.

A structure to support future growth plans

As a result, the clients successfully minimised their US exit tax, achieved UK residency coupled with US non-residency, and implemented a new business structure. 

This new structure is designed to deliver a globally efficient tax rate for the owners, ensuring strategic tax optimisation across international borders - now, and as the business grows. 

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