Payroll and statutory accounts for companies employing in the US and the UK
The moment someone works for you in the other country, you take on a second set of payroll rules. We run UK PAYE and US payroll, keep seconded staff in the right social security system, and prepare UK accounts that agree with your US reporting.
Free and no obligation. You get a written scope and fee before any work starts.
The payroll and accounts we run for you
Both payrolls and both sets of books, run by one team.
- UK PAYEPayroll run and reported to HMRC through Real Time Information.
- US payrollFederal, FICA and state withholding, with Form 941 and year end filings.
- SecondmentsCertificates of coverage and shadow payrolls for staff working abroad.
- UK accountsStatutory accounts under FRS 102, filed at Companies House.
- US GAAPReporting packs for a US parent, reconciled with the UK accounts.
When payroll gets complicated across the border
These are the moments employers in the corridor usually need help.
You are hiring your first person in the other country
A salesperson in New York or an engineer in Manchester, often before you have a local company.
The risk: getting payroll wrong from the first payslip means back tax, penalties and an unhappy new hire.
You are sending someone to work abroad
An employee is moving to the other country for months or years but staying on your payroll.
The risk: without a certificate of coverage, social security can be charged in both countries.
Someone moved abroad and kept working for you
An employee now works from the other country, sometimes without payroll knowing.
The risk: you may owe withholding there, and their work can create a taxable presence for the company.
Your UK and US numbers never agree
Your UK subsidiary files FRS 102 accounts while the US parent reports in US GAAP.
The risk: mismatched books slow the year end and raise questions from auditors and investors.
Who runs payroll for your employee, and where?
Two quick questions. You will see where income tax is withheld, which social security system applies and what you need to register.
How the checker works: it covers the four employment situations most common in the corridor. These are a UK company hiring someone who lives in the US, a US company hiring someone in the UK, and employees seconded in either direction. For each, it shows who withholds income tax, which country’s social security applies and which registrations are needed. For example, a UK employee seconded to the US for two years usually stays in UK National Insurance with a certificate of coverage, while US federal and state income tax is withheld from their US pay.
What we do for you
Both payrolls and both sets of books, run by the same team.
UK payroll under PAYE
Payroll run and reported to HMRC through Real Time Information, with National Insurance, statutory pay and auto enrolment handled.
US payroll and withholding
Federal, FICA and state withholding, with quarterly Form 941 filings and year end Forms W‑2 and 940.
Secondments and shadow payroll
Certificates of coverage, shadow payrolls and tax equalisation for employees working in the other country.
UK statutory accounts
Annual accounts under FRS 102, filed at Companies House and prepared alongside the corporation tax return.
US GAAP reporting packs
Monthly or quarterly packs for a US parent, with FRS 102 to US GAAP adjustments explained.
Bookkeeping in two currencies
Books kept in pounds and dollars, with intercompany balances reconciled every month.
What clients say about our payroll and accounts work
First US hire, set up correctly
We hired our first engineer in Texas without a US company. Taxule registered us as a foreign employer, set up federal and state withholding, and flagged the permanent establishment point before it became a problem.
No social security paid twice
Two of our managers moved to London for three years. Taxule got their US certificates of coverage in place and ran the UK shadow payroll, so nobody paid social security in both countries.
UK and US numbers that finally agree
Our UK accounts and the US parent reporting used to disagree every quarter. Now one team prepares both from the same books and the reconciliation is done before we ask.
How we work with you
Three stages, handled by one team across both countries.
Map your people
We list who works where, who employs them and for how long, then confirm the tax and social security position for each person.
You get: a clear position for every employee before anything is registered.
Set up the payrolls
We register the employer on each side, apply for certificates of coverage and set up shadow payrolls where needed.
You get: payrolls ready before the first pay date, on both sides.
Run, report and reconcile
We run payroll each month, file the returns in both countries and reconcile the books into your accounts.
You get: payslips, filings and accounts that agree with each other.
Why one team for both payrolls
Many employers use a UK payroll bureau and a separate US provider. This is what changes when one team runs both.
The payroll rules behind your position
The rules that decide who withholds what, explained in plain English.
Tax follows where the work is done
Employment income is generally taxed where the duties are performed. A UK employee working in New York is within US tax on those workdays, even if paid from London.
US and UK treaty, Article 14Social security has its own agreement
The US and UK social security agreement stops contributions being paid in both countries. A seconded worker expected to stay up to five years usually stays in their home system.
US and UK Social Security AgreementThe 183 day test is narrower than it sounds
The treaty exemption only works if the employee is present 183 days or fewer in a 12 month period and a local employer or permanent establishment does not bear the cost.
US and UK treaty, Article 14(2)US states follow their own rules
Federal withholding may be exempt under the treaty while state income tax is still due, because US states are not bound by it.
Employees can create a taxable presence
Staff in the other country, particularly those who negotiate or sign contracts, can create a permanent establishment for the employer.
US and UK treaty, Article 5Two sets of accounts, one group
A UK private company files accounts at Companies House within nine months of its year end, while the US parent reports in US GAAP. The two must reconcile.
Companies Act 2006, section 442Your payroll and accounts questions
Straight answers to what HR and finance teams ask us first.
Can a UK company employ someone in the US without a US company?
Yes. It can register as a foreign employer with the IRS and the state, or use an employer of record. It should first check whether the employee’s work creates a US permanent establishment.
Does a US company need to run UK PAYE for a UK employee?
If it has a UK presence, yes. Without one, it can register with HMRC as an overseas employer. Otherwise the employee may need to pay their own tax and National Insurance.
Which country’s social security applies to a seconded employee?
Under the US and UK social security agreement, an employee seconded for up to five years usually stays in their home system, with a certificate of coverage.
What is a shadow payroll?
A payroll run in the host country to report and pay local income tax for an employee who is still paid through their home country payroll.
When are UK statutory accounts due?
A private company must file its accounts at Companies House within nine months of the end of its accounting period, as well as filing its corporation tax return.
How much does cross border payroll cost?
It depends on how many employees and payrolls are involved. After the free consultation, we agree the scope and fee with you in writing before any work starts.
Pay your people correctly on both sides from the first payslip.
Tell us who works where. We will map the payroll, social security and accounts you need, and set them up before the next pay date.
