Guides/UK Ltd vs US LLC
Head to head · 2026

The LLC's 0% is real. Whether it reaches you is a different question.

No US tax at entity level does not mean no tax. Your customers decide which payment rails you need; where you live decides what the pass-through actually costs. Set both below.

0%
US federal, qualifying LLC
No ECI, non-US owner
19-25%
UK Ltd, all profit
Distributed or not
$25k
Penalty per missed 5472
Per form, per year
Option A
UK Ltd
Companies House Limited, a taxable corporation at 19% to 25%
£100 to form24-hour setup130+ treaties
vs
Option B
US LLC
Pass-through, no entity-level federal tax, taxed in your hands
Pass-throughStripe USWyoming privacy
Where are your customers?
Where do you personally live?
US LLCUS customers · UK resident

Take the LLC for the rails, but expect HMRC to tax it as opaque.

Stripe US and American enterprise procurement are worth the paperwork. Be aware that HMRC has historically treated US LLCs as opaque rather than transparent, which can mean UK tax on distributions rather than a clean pass-through, and complicates double-tax relief. Get UK advice before you form.

US federal tax
0% with no ECI
UK treatment
Often opaque
Watch
Double-tax relief on distributions
General guidance, not advice. Treatment of a US LLC varies materially between countries, confirm locally before forming.

Sixteen factors, side by side

UK 7 · US 5 · tied 4
Factor
UK Ltd
US LLC
Formation cost
£100 online at Companies House
Wins
$102–110 state fee + $50–150 agent
Entity-level tax
19% below £50k, 25% above £250k
None federally, pass-through by default
Wins
Classification
Separate taxable corporation
Disregarded entity or partnership
Wins
Minimum capital
£1
None
Setup time
24 hours
Wins
1–10 days, expedited available
Foreign ownership
100%
100%
Local presence
No director or agent required
Wins
Registered agent required in-state
Annual running cost
£200–1,000 including accounts
Wins
$60–300 state + $500–1,500 tax prep
Non-resident banking
Wise, Revolut, Starling, Monzo, Tide
Wins
Mercury, Relay, Brex
Payment processing
Stripe UK, GoCardless
Stripe US, Shopify Payments, full merchant services
Wins
Market credibility
Strong across Europe and the Commonwealth
Strong with US enterprise buyers
Tax treaties
130+
Wins
70+
Audit
Only above two of three thresholds
Never required for an LLC
Wins
Mandatory filings
Confirmation statement and annual accounts
Wins
Form 5472 with pro-forma 1120, every year
Owner privacy
Directors and PSCs public
Members can stay private in Wyoming or New Mexico
Wins
Best suited to
European and global consultancies, simple operations
US-market SaaS, e-commerce, payment-rail dependent

The case for each

UK Ltd
Cheapest, fastest, easiest to bank

A private company limited by shares, registered at Companies House: £100 online, live within 24 hours, no notary, no minimum capital, no local director, no mandated accountant. More than 500,000 are formed each year and a substantial share are owned by non-residents.

The fee was £12 until 1 May 2024, when Companies House quadrupled it to £50, and it doubled again to £100 on 1 February 2026, most comparisons still quote the old number. The confirmation statement also rose to £34. Budget £200–1,000 a year all in for a lightly trading company.

Corporation tax is 25% above £250,000, 19% up to £50,000, with marginal relief between, charged on all profit whether retained or distributed. A CT600 is due annually with payment nine months and a day after year end. Dividends to non-resident shareholders suffer no UK withholding; UK-resident shareholders pay 10.75% to 39.35% above a £500 allowance. VAT registration is mandatory above £90,000.

Corporation tax
19–25%
Formation
£100 online
Setup
24 hours
Running cost
£200–1,000/yr
For
+Among the cheapest formations of any major jurisdiction
+24-hour online incorporation
+Excellent non-resident banking, Wise, Revolut, Starling, Monzo, Tide
+Universally recognised corporate form
+No audit for small companies
+130+ tax treaties, the broadest network here
Against
19–25% on all profit, not only distributions
Accounts, directors and PSCs are public
Post-Brexit EU VAT is heavier to administer
HMRC scrutinises non-resident-owned dormant companies
Identity verification now mandatory at Companies House
US LLC
Pass-through taxation, American payment rails

A state-law entity, most often formed in Wyoming, Delaware, New Mexico or Florida, combining corporate limited liability with partnership tax treatment. By default a single-member LLC owned by a foreign person is a disregarded entity, invisible to the IRS as a taxpayer, and a multi-member LLC is a partnership. Both are pass-throughs.

The draw is the package: US banking through Mercury, Relay or Brex; US payment rails through Stripe, PayPal and Shopify Payments; American brand credibility with enterprise buyers; and potentially no federal tax. Federal tax applies only to effectively connected income, so an owner abroad serving non-US clients with no US office or employees typically has none.

The obligations are administrative but unforgiving. An EIN takes four to eight weeks by fax without an SSN. Form 5472 plus a pro-forma Form 1120 must be filed annually regardless of activity, at $25,000 per missed form per year. Wyoming costs $102 to form and $60 a year; Delaware $110 plus $400 annual tax.

Federal tax
0% with no ECI
Formation
$102–110 + agent
EIN wait
4–8 weeks
Tax prep
$500–1,500/yr
For
+No entity-level US tax for qualifying foreign-owned LLCs
+Stripe, PayPal, Shopify and full US merchant services
+US brand credibility with enterprise customers
+Mercury, Relay and Brex all onboard non-resident LLCs
+Member privacy in Wyoming and New Mexico
+No audit requirement, ever
Against
Form 5472 mandatory, $25,000 penalty per miss
EIN takes 4–8 weeks without an SSN
Your home country may treat the LLC as opaque, risking double tax
US CPA fees of $500–1,500 a year
Any US-source income pulls you into ECI and 1040NR territory

Which one is yours

Choose UK Ltd if…
Your customers are mainly in the UK, EU or Commonwealth
You want the cheapest, fastest route to a live company
You want day-one banking with Wise, Revolut, Starling or Monzo
You prefer one confirmation statement and one set of accounts
You would rather not file anything to a foreign revenue service
You or your shareholders are UK resident and will draw salary and dividends
Choose US LLC if…
Your customers are mainly in the United States
You need Stripe US, PayPal, Shopify Payments or US merchant services
You are a non-US resident with no US-source income
You run e-commerce, SaaS or info products aimed at American consumers
Owner privacy matters and Wyoming or New Mexico suits you
You are willing to pay a US CPA for annual Form 5472 compliance
Our verdict

Let the payment rails decide, not the tax rate.

If your revenue depends on Stripe US, Shopify Payments or American enterprise procurement, a Wyoming or Delaware LLC wins despite the IRS paperwork, no UK entity substitutes for a US merchant account. If you invoice European or global clients, the UK Ltd is cheaper, simpler and files nothing to a foreign revenue service.

The pass-through's headline 0% should not settle it. That figure describes the US federal position only, and for most founders the real bill is set by their own country of residence. Many eventually run both: a UK Ltd operating company with a US LLC as the American invoicing entity.

The Form 5472 trap

The single most expensive mistake in this comparison, and it catches people who owe no US tax at all.

Form 5472 applies even at zero activity
Every foreign-owned single-member LLC files it annually alongside a pro-forma Form 1120, whether or not it traded. The $25,000 penalty is per form, per year, and the IRS applies it mechanically.
The EIN gates everything
Without an SSN the SS-4 goes by fax or mail and takes four to eight weeks. Your bank account, Stripe account and first invoice all wait on it. Apply the day the company is formed.
Opaque classification at home
The UK and several EU states may treat a US LLC as a corporation rather than a pass-through. The US sees transparent, your country sees opaque, and the same profit gets taxed twice with limited relief.
US-source income changes everything
US employees, a US office or services performed in the US create effectively connected income, a Form 1040NR obligation and genuine US tax. The 0% story holds only while none of those exist.
A foreign-owned single-member LLC files Form 5472 with a pro-forma Form 1120 every year, even with zero US income and zero activity. The penalty is $25,000 per form, per year.
Common questions
Ready to decide?

Check how your country treats an LLC first.

Opaque versus transparent classification is the difference between a clean pass-through and being taxed twice on the same profit.

Country comparisonAdd Estonia or Ireland as a third option.Tax calculatorModel the entity-level bill.Cost estimatorFormation plus the first year.Document checklistWhat each registry and the IRS want.

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