HMRC could easily deem the company as being controlled in the UK[0]. This could potentially cause you problems, but then again the corporate tax rate in the US

HMRC could easily deem the company as being controlled in the UK[0]. This could potentially cause you problems, but then again the corporate tax rate in the US is considerably higher so would there be any tax owed considering the double-taxation agreement[1]? [0] http://www.menzies.co.uk/wp-content/uploads/2016/01/INTERNATIONAL-Inbound_2015_01_Management-and-Control-of-UK-subs.pdf http://www.menzies.co.uk/wp-content/uploads/2016/01/INTERNAT... [1] https://www.gov.uk/government/publications/usa-tax-treaties https://www.gov.uk/government/publications/usa-tax-treaties