For a founder who lives outside both countries, a UK limited company and a US LLC are the two most common ways to get an English-language company that customers, marketplaces and payment platforms recognise. They look similar from a distance and work very differently underneath: one is a taxpayer in its own right, the other usually isn’t. This post compares them side by side. The details are in our two guides: UK limited company for non-residents and US LLC for non-residents.
Side by side
| UK limited company | US LLC (single owner) | |
|---|---|---|
| Form it | £100 online with Companies House, usually within 24 hours, once every director has verified their identity | $110 in Delaware or $100 in Wyoming; quick, then an EIN by phone, fax or mail (4–5 weeks by mail) |
| Local requirement | A UK registered office address and a registered email address | A registered agent in the state |
| Who the public can see | Directors and people with significant control (names, service address, month and year of birth) | Not the members: the formation document needs only the name and registered agent; no FinCEN report since August 2026 |
| How it is taxed | A UK taxpayer: UK resident by law, corporation tax at 19% to 25% | Ignored for US income tax by default; the owner is taxed in the US only on income connected with a US business or other US-source income |
| Paying you | Dividends, with no UK withholding tax | Profit is treated as yours for US tax; your home country decides how it taxes you |
| Yearly filings | Confirmation statement (£50), accounts and a company tax return | State fee ($400 Delaware, from $60 Wyoming), plus Form 5472 with a pro forma 1120 |
| If you miss them | Late accounts: £150 to £1,500, doubled if late two years running | Form 5472: $25,000 penalty; state: penalty or dissolution |
Sources: GOV.UK: register a company · Companies House: public record · CTA 2009 s.14 · UK corporation tax rates · UK late filing penalties · 6 Del. C. §18-201 · IRS: single-member LLCs · IRS: Form 5472 instructions · IRS: nonresident taxation · FinCEN: BOI
The real difference: who pays the tax
A UK company is a taxpayer. It is UK resident because it was incorporated in the UK, and it pays corporation tax on its profits, wherever its director lives. If it is run from another country, that country may claim it too; see where is your company really managed?
A single-member US LLC owned by a non-US person is, by default, ignored for US income tax. The US taxes the owner only on income connected with a US business or certain other US-source income. Whether the owner owes any US income tax depends on whether the income is connected with a US business, a question for an adviser. Either way the question doesn’t disappear: much of it moves to your home country, which may look through the LLC and tax you on its profit, or treat it as a foreign company. Ask an adviser where you live which it is before you choose.
Privacy: the US shows less
The UK publishes directors and people with significant control on a register anyone can search, with a service address and month and year of birth; home addresses and full dates of birth stay private. A Delaware or Wyoming LLC’s public filing doesn’t name its members, and since August 2026 US-formed companies don’t report beneficial owners to FinCEN. Your bank, your registered agent and the IRS still know who you are.
Yearly admin: different, not lighter
A UK company files a confirmation statement, annual accounts and a company tax return, all through commercial software now that HMRC’s free service has closed. A US LLC files far less with its state, but a foreign-owned single-member LLC must send the IRS Form 5472 with a pro forma Form 1120 every year, by fax or mail, even with no income. The $25,000 penalty for missing it is the single most expensive mistake in this comparison.
VAT and sales tax
A UK company selling to UK customers may need to register for VAT, and if its only UK presence is a registered or virtual office, HMRC may not treat it as UK-established, which removes the usual £90,000 threshold. A US LLC selling to US customers can face sales tax in the states where it sells; that depends on each state’s rules. Both are questions for an adviser before your first sale.
Sources: VAT Notice 700/1 · HMRC: online filing service closure
Which one?
- UK limited company if your customers are mainly in the UK or Europe, you want a company that is a taxpayer in its own right and pays you dividends, and you are comfortable with a public register.
- US LLC if your customers or platforms are mainly in the US, you want your owners off the public record, and your home country’s treatment of an LLC works for you.
- Neither if your customers are in Asia: compare Hong Kong and Singapore in best country to incorporate.
An example
Invented for illustration. Ines lives in Buenos Aires and sells online courses, about half to US students and half to UK and European ones. She compares the two with her adviser. A US LLC would keep her name off a public register; a UK company would pay UK corporation tax and raise VAT questions from her first UK sale. Her adviser explains how Argentina would treat each. Because most of her payment platforms and customers are American, she chooses a Wyoming LLC, and puts the Form 5472 deadline in her diary before anything else.
Not sure which fits?
We form UK limited companies (with the registered office through our UK partner) and US LLCs in Delaware and Wyoming. Tell us where your customers are and where you live, and we’ll help you and your adviser choose.
Compare them with usFrequently asked questions
Is a UK Ltd or a US LLC better for a non-resident?
It depends on where your customers are and how your home country taxes each. A UK company is a UK taxpayer and publishes its directors and owners; a single-member US LLC is ignored for US income tax by default and keeps members off its public filing, but must file Form 5472 every year.
Does a UK company owned from abroad pay UK tax?
Yes. A company incorporated in the UK is UK resident by law and pays corporation tax at 19% to 25%, wherever its director lives. Its home-country owner may also be taxed on dividends there.
Does a US LLC owned by a non-resident pay US tax?
Not as a company, by default. A single-member LLC is ignored for US income tax, and the foreign owner is taxed in the US only on income connected with a US business or other US-source income. It still files Form 5472 with a pro forma Form 1120 every year.
Which is more private, a UK Ltd or a US LLC?
A US LLC. The UK publishes directors and people with significant control. Delaware and Wyoming LLC filings don’t name members, and since August 2026 US-formed companies don’t report owners to FinCEN.
Which costs more to keep each year?
It depends on your accountant’s fees. In government fees, a UK company pays £50 for its confirmation statement but also has to prepare accounts and a tax return every year; a US LLC’s state fee is $400 in Delaware or from $60 in Wyoming, plus its Form 5472 filing.
General information for internationally mobile founders, not tax, legal or immigration advice for your situation. Rules and fees change; confirm your position with a qualified adviser in each country involved before acting.