The work and the person cannot be separated on an invoice

An agency or consultancy may sell globally while the owner performs the core work from one country. Forming a foreign company changes the contracting entity; it does not physically move that work. The structure needs to reflect the people creating and supervising the service.

We distinguish an owner-operated practice from a larger agency with a distributed delivery team and real management functions. Relocation may create different options from remaining at home, and that choice belongs near the start of the conversation.

Source and taxable presence need their own analysis

The country of the customer, the bank or the incorporation is not enough to characterise the service. Examine where it is performed, who contracts, who has authority and whether the activity creates obligations where the people work.

The IRS, for example, generally locates personal-service income where the work takes place. That illustrates the need to examine the applicable rule rather than assume all foreign invoicing produces foreign-source income. Other jurisdictions and income categories require their own analysis.

References [1]

The facts that shape the recommendation

Part of the business or planWhat we examine
OwnerPersonal residence, workdays, role and willingness to relocate.
DeliveryEmployees, contractors, supervision and locations of client work.
ContractsLegal supplier, signature authority, scope and customer requirements.
EconomicsFees, subcontractor costs, related-party charges and owner withdrawals.

Separate a founder move from a company restructure

A move can require departure and arrival planning, work permission and banking changes. A company restructuring may instead require new contracts, team arrangements and a different management process. Sometimes both are needed, but they should not be treated as the same transaction.

Before moving clients to a new entity, identify customer consent requirements and responsibility for existing deliverables, disputes and refunds. Keep the commercial relationship clear throughout the transition.

Common mistakes to avoid

  • Assuming a foreign company removes tax on work still performed at home.
  • Using a director appointment as a substitute for genuine management.
  • Ignoring employment or contractor obligations where delivery happens.
  • Comparing savings without the cost of the proposed operational change.

Choose a scope that fits the practice

A focused advisory engagement may resolve the owner’s relocation question. A larger agency may benefit from a full structuring and implementation project. We also assist with defined company, banking or residency needs when the wider position is already understood.

Start with where you live and work, the size and location of the team, client markets and the main objective. Let us know whether you can realistically move or delegate meaningful decisions.

Sources & research notes1 reference

Sources supporting this guide. Research draft awaiting editorial review.

  1. IRS: source of personal service income