The Latest on the Global Tax Agreement: Why Expanding Your Business to the United States is a Smart Move
- Andrew Sones
- Aug 18, 2025
- 3 min read
The international tax landscape has shifted. With the OECD’s global tax agreement now being implemented by over 130 countries—including the UK—businesses are re-evaluating where they should operate to remain competitive. For many British companies, these changes make expanding into the United States more attractive than ever.
The agreement, formally known as the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), is designed to ensure profits are taxed where economic activity actually takes place. With a global minimum corporate tax of 15% effectively eliminating the benefits of traditional "shell" tax havens, the focus has shifted back to jurisdictions that offer genuine market depth and legal stability.
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What the 15% Global Minimum Tax Means for You
The implementation of "Pillar Two" of the OECD agreement means that if a company’s profits are taxed below 15% in one country, its home country can apply a "top-up" tax. For UK businesses, this means:
Elimination of Offshore Benefits: The tax advantage of holding intellectual property or profits in low-tax jurisdictions is largely gone.
Emphasis on Economic Substance: Taxing authorities now prioritize where your employees, offices, and sales are located.
Simplified Compliance: While the rules are complex, they create a more level playing field for companies operating in transparent, high-growth markets like the U.S.
[Image comparing the OECD global tax framework vs. traditional offshore structures]
Why the United States is the Premier Destination in 2026
In this new environment, the United States stands out not just as a market, but as a strategic "safe harbor."
Massive Internal Market: Direct access to over 330 million consumers with high disposable income.
Generous R&D Credits: While the federal corporate rate is 21%, the U.S. offers significant Research & Development (R&D) tax credits and state-level incentives that can bring the effective rate down significantly for innovative firms.
Capital Access: The U.S. remains the world’s deepest market for venture capital and private equity, essential for scaling UK startups.
Legal Protections: Strong intellectual property (IP) laws and a predictable judicial system provide a level of security that "haven" jurisdictions simply cannot match.
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Essential Immigration Pathways for Expansion
Establishing a U.S. presence requires moving your most trusted talent. Under the US-UK Treaty of Commerce and Navigation, British businesses have access to several streamlined visa categories:
E-2 Treaty Investor Visa: Perfect for entrepreneurs and small-to-medium enterprises (SMEs) investing a "substantial" amount into a U.S. business.
L-1 Intracompany Transfer: Ideal for larger firms moving executives or managers from a UK parent to a U.S. branch.
EB-5 Immigrant Investor: For those seeking a permanent Green Card through significant capital investment that creates at least 10 U.S. jobs.
How Crownside Legal Bridges the Gap
Based in London, Crownside Legal specializes in helping UK companies navigate the intersection of U.S. business law and immigration. Led by Attorney Andrew R. Sones, a member of the American Immigration Lawyers Association (AILA) and the American Bar Association, we ensure your expansion is compliant, strategic, and successful.
Frequently Asked Questions
Does the 15% minimum tax apply to small businesses?
While the primary focus of the OECD agreement is on large multinationals (with revenues over €750m), the "Pillar Two" logic is being adopted into national laws that affect smaller entities. Navigating these early ensures you are "future-proofed."
Can I manage my U.S. business from London?
While you can own a U.S. business from abroad, U.S. tax and immigration authorities increasingly look for "economic substance." Having a physical office and authorized staff in the U.S. via an E-2 or L-1 visa is often the best way to prove this.
What is the "Top-Up" tax?
If your U.S. entity’s effective tax rate falls below 15% due to specific credits, your UK parent company may be required to pay the difference to the HMRC. We work with tax professionals to ensure your structure is optimized for both jurisdictions.
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Turn Global Tax Changes into Your Competitive Advantage
The era of "shell" companies is over. The era of direct American expansion has begun. Secure your foothold in the world's most resilient economy today.
Schedule a Free Consultation: www.calendly.com/crownside
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