July 21, 2026 · Gullia Filing Editorial
US LLC vs UK Ltd for Non-Residents
Choosing between a US LLC and a UK Limited Company as a non-resident founder? Compare tax, banking, compliance, and setup costs side by side.
Quick answer
Choose a US LLC if you sell digital services or products mainly in USD, want a native US Stripe and Mercury setup, and want the lowest ongoing cost. Choose a UK Ltd if your customers, staff or credibility are in the UK or EU, you need UK VAT registration, or you want a recognised Companies House registration.
Both allow 100 percent foreign ownership, both can be formed remotely, and both carry annual filings you cannot skip. Neither is a tax shelter: where you live and where you work usually decides your personal tax.
Side by side: US LLC vs UK Ltd (2026)
| Factor | US LLC (WY / DE) | UK Ltd (Companies House) |
|---|---|---|
| Time to form | 1 to 3 business days | Same day to 24 hours |
| State or filing fee | 100 to 300 USD | 50 GBP (online) |
| Non-resident allowed | Yes, 100% foreign ownership | Yes, 100% foreign ownership |
| Default tax treatment | Pass through (single member disregarded) | Corporation Tax on worldwide profits |
| Corporate tax rate | 0% at entity level if pass through | 19% small profits, up to 25% |
| Annual filing | State report + IRS Form 5472 / pro forma 1120 | Confirmation Statement + annual accounts |
| Public register of owners | Limited in WY and NM | Directors and PSCs are public |
| Registered address | Required in state of formation | Required in the UK |
| Banking (fintech) | Mercury, Wise, Relay, Brex | Wise, Revolut Business, Tide |
| Stripe access | Native US account | UK account with SCA |
| VAT / sales tax | State by state sales tax nexus | UK VAT threshold 90,000 GBP |
| Best for | Digital services, SaaS, e-commerce to the US | UK and EU clients, agencies, consultancies |
Liability protection
Both structures separate the business from the owner personally, so business debts and claims normally stop at the entity. Both also lose that protection in similar ways: mixing personal and company money, signing a personal guarantee, trading while insolvent, or failing to keep the entity in good standing. A UK director additionally carries statutory duties under the Companies Act, including wrongful trading exposure. An LLC member relies on the operating agreement and on the state statute, and courts can pierce the veil where the company is run as an alter ego.
Formation, step by step
US LLC. Pick a state, check the name, appoint a registered agent with a street address in that state, file the Articles of Organization, adopt an operating agreement, then apply for an EIN. Non-residents without an SSN or ITIN apply for the EIN on Form SS-4 by fax or mail, which is the slowest step in the process.
UK Ltd. Choose a company name, a UK registered office, at least one director and one person with significant control, allocate shares, and file the incorporation at Companies House. Directors must complete Companies House identity verification. Register for Corporation Tax with HMRC within three months of starting to trade.
Tax treatment in plain English
US LLC, single member, non-resident owner. By default the IRS treats the LLC as a disregarded entity. If none of the income is Effectively Connected with a US Trade or Business and there is no US permanent establishment, the entity typically owes no US federal income tax. You still file Form 5472 with a pro forma 1120 every year, and the penalty for missing it starts at 25,000 USD. Read the Form 5472 and 1120 filing guide before your first deadline. States may still charge annual fees or franchise tax regardless of profit.
UK Ltd. The company pays UK Corporation Tax on worldwide profits: 19 percent small profits rate up to 50,000 GBP, tapering to 25 percent above 250,000 GBP. Directors can take salary, dividends or a mix, each taxed differently in their own country of residence. Because the company is UK tax resident, profits earned from customers outside the UK are still within the UK charge. That is the central trade off against a US LLC.
Neither summary replaces advice for your own residence. Your home country may tax the profits anyway under controlled foreign company, place of effective management or personal residence rules.
Ongoing compliance side by side
| Obligation | US LLC | UK Ltd |
|---|---|---|
| Annual state or registry filing | Annual or biennial report, fee varies by state | Confirmation Statement, 34 GBP online |
| Financial statements on public record | Not required in most states | Annual accounts filed at Companies House |
| Federal or national return | Form 5472 with pro forma 1120 if foreign owned | CT600 Company Tax Return to HMRC |
| Registered address | Registered agent in the formation state | UK registered office, an appropriate address |
| Indirect tax | Sales tax where you have nexus | VAT once turnover passes 90,000 GBP |
| Payroll | Only if you have US employees | PAYE and pensions if you employ in the UK |
Missing a UK accounts deadline creates an automatic penalty from 150 GBP; the detail is in our guide to filing annual accounts with Companies House. Missing a US state report can put the entity into bad standing and eventually administrative dissolution.
Banking access for non-residents
Banking is usually the real bottleneck, not formation.
- US LLC: Mercury and Relay open remotely with a passport, formation documents and an EIN. Wise adds multi currency. Stripe activates in days once the EIN is issued.
- UK Ltd: Wise Business, Revolut Business and Tide open remotely for verified directors. High street banks normally want an in person meeting and often a UK resident director.
Choose based on where your customers pay from and which payment processor you depend on, not on where you personally live.
Annual maintenance costs
Rough all in cost per year, including registered address and light bookkeeping:
- Wyoming LLC: 250 to 600 USD
- Delaware LLC: 450 to 900 USD, including the 300 USD franchise tax
- UK Ltd: 300 to 900 GBP, covering the Confirmation Statement, accounts and registered office
Accounting fees sit on top once you are trading properly. See company registration cost by country and current Gullia Filing pricing.
Can you have both?
Yes, and many cross border founders do: a UK Ltd invoicing UK and EU clients in GBP and EUR, and a US LLC billing US clients in USD and holding a US Stripe account. Two entities means two sets of filings and a transfer pricing question if they trade with each other, so only do it when the revenue justifies it.
Decision framework
Pick a US LLC if two or more apply:
- Your customers pay primarily in USD.
- You need a native US Stripe, Mercury or Relay account.
- You want the lowest possible annual cost.
- You want member privacy on public filings.
Pick a UK Ltd if two or more apply:
- Your customers are in the UK or EU.
- You plan to hire staff or contractors in the UK.
- You need VAT registration for B2C sales in Britain.
- You want a Companies House registration for local credibility.
Still unsure which state suits a non-resident LLC? Compare options in our guide to the best state to form an LLC for non-residents.
Next step
Gullia Filing forms US LLCs and UK limited companies remotely, obtains EINs for founders without an SSN, and files the annual reports, Form 5472 and Companies House accounts afterwards through Business Maintenance and Tax and Accounting. If you want a recommendation before you spend anything, schedule a call.
Questions about: US LLC vs UK Ltd for Non-Residents
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A US LLC suits founders selling digital services in USD who want a native US Stripe and the lowest annual cost. A UK Ltd suits founders whose customers, staff or credibility sit in the UK or EU, or who need UK VAT registration. Both allow full foreign ownership and remote formation.