Continuing to work for my US employer after moving to the UK

I'm a dual UK/US citizen working for a small US tech. company.  I want to move to the UK this summer and my company would like me to continue to work for them.  It seems I have a couple of options

1) Have my company create a UK company and payroll and become a PAYE employee in the UK.

2) Resign and become self employed, run my own personal service company (PSC) which will invoice them and then I deal with UK/US taxes.

Can anyone advise me on a person/company who might be able to do either of these services who is familiar with UK and US tax implications for myself and my employer ?   I'm not looking for free advice here: I need a real contact of a person or company who could setup either of these options, run the numbers and find out whether one is preferable to the other.

Thanks in advance ! 

Option 2) is the simplest....although if you have only a single client you must make sure you qualify to be self employed according to HMRC.

Thanks Nun - I had assumed that filing US taxes would be horrendously complicated if I'm the sole employee of a UK company (I know it can be if you try the UK tax "dodge" of paying yourself in dividends instead of salary, but that wasn't my intent).

I have found someone in the UK who can setup the whole PSC and do UK taxes but she's not familiar with US taxes, which might be a problem.

If you know of someone let me know

Thanks

It's not difficult to set up as self employed in the UK....certainly far easier than your US employer trying to open a UK company to employ you. It's similar to being a sole proprietor in the UK and the taxes aren't that hard. Just pay your UK tax and NI, maybe VAT. You can exclude your UK self-employment income from US tax using FEIE or use FTCs.

Thanks again Nun.  I guess my main worry is that as a sole employee of a PSC the US will require some obscure documentation as owner of a foreign company, and further I may fall into the trap of paying double self employment tax - to the UK and to the US.

Under the US/UK SS Totalization Agreement you don't pay US self-employment tax on UK self employment income, but you do have to pay the UK equivalent.

We have experts for both the US and UK side of things who can offer advice and guidance on how you would be taxed should you make the move abroad.

This video is a great starting point for how you would be taxed as an American living in the UK: http://www.greenbacktaxservices.com/blog/us-expat-taxes-living-in-the-uk/

We also have many more free resources on our website if you would like to check them out

From a UK perspective the word "contractor" and the indicia of self-employment have a very different meaning from within the United States. If you are likely to be treated an employee you would be entitled to a UK employment contract, leave allowance, maternity/paternity pay, sick pay etc under English (or Scottish) law.

Your existence might constitute a permanent establishment of the US company so requiring filing of UK corporate tax returns.

The turnover may be subject to VAT.

You will still need to pay UK tax & NIC on the income.

Generally speaking it is best that the engager of the services takes advice in the UK so that it is regulated in the UK, which is where the work will be carried out. Advice of the kind described would always be best paid for by the engager of the services as they are taking much of the risk.

Persons working in the UK for a foreign employer need to register as such for NIC purposes and pay their own income tax. The procedure is more or less the same as that for UK-resident employees of diplomatic missions and foreign government agencies. Here's an unofficial explanations:
http://taxaid.org.uk/guides/information/special-groups-carers-students-migrant-workers-and-moving-abroad/migrant-workernew-to-the-uk/overseas-employers
and
http://www.accountingweb.co.uk/anyanswers/nic-payable-foreign-employer

I have not found current HMRC instructions online but their former instructions for embassy employees is here:
http://webarchive.nationalarchives.gov.uk/+/http://www.hmrc.gov.uk/employers/new-emp-spec-arran.htm ("... If you think this applies to you please call your local HM Revenue & Customs office."

The end result is (unless the practice has changed) that the foreign employer is excused their share of NICs and only the employee's NICs are collected.

If the employee is a senior officer of the firm or if for any other reason the foreign firm is deemed to have a permanent establishment in the UK then it must register for PAYE as normal. Or it may voluntarily do so: this may be convenient if the firm has several low-paid UK employees. I knew of a Canadian firm that hired students in the UK; these students were at low wage so NICs were a non-issue.

There are two other points: If the work is on behalf of a UK customer then that customer firm may be liable to handle the PAYE including NICs. Or the foreign firm may choose to enter into an "employee leasing" arrangement with a UK company that handles clients' payroll arrangements and pays their workers' wages.

Thanks everyone - a lot to think about.