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US LLC vs UK LLP/LTD for european

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fifcbc

New member
Sep 2, 2021
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France
#1
Hi there,
I'm going to sell my product (only in USA for the moment) with Amazon FBA/US fulfillment centers, and i'm wondering which option would be the best to pay the lowest taxes possible.

Knowing that i want to leave France to live either in Portugal or in London.

1/ Should I open an US LLC or a UK LLP/LTD ?

2/ Am I ETBUS or Non-ETBUS ? (some said i am non etbus cause amazon dont work only with me. But others said that i am etbus so I should pay federal tax in US and not in portugal/UK


What arrangement would be the best for me ?

Thank you!
 
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#2
I don't think you would be ETBUS, but that's really a question for an accountant. Typically FBA is given as an example for NOT having ETBUS, like you said.
If you are not ETBUS, your company will be taxable where you are anyway. If you sell primarily to US customers, forming a US LLC will probably be best in terms of marketing. But it probably won't make a difference for your taxes.
Beware that France has exit tax, so any company you incorporate before moving to another country may be subject to tax. It will probably be better to move, before you register the company.

If I were you, I would do it in this order:

1. Ask a US accountant if you would be ETBUS (the answer should probably be no and it should not depend on the entity you choose)
2. Decide where you want to move (Portugal or UK)
3. Talk to an accountant from Portugal/UK and ask how a US LLC would be treated/if a local company would be better
4. Talk to a French accountant if it could be an issue if you register that type of company before you move

Yes, it's unfortunate that so many countries are involved, but you won't find anyone who's familiar with all countries' laws, unless you pay a ton of money for advice from PwC or a similar company.
 
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#5
The suggestion to speak with an accountant is definitely key here.
Just be sure to get the right one.

My situation is "similar" to yours, with of course some exceptions:
- I do sell services to customers in Europe and US;
- I've a UK LTD with a non-resident status (I'm a EU citizen not resident in UK). For more info about UK LTD non-resident please refer to other posts in the Forum.
- I take advantage of paying zero corporate Taxes to UK and zero taxes in the country I live thanks to DTA
- I use a specific setup to not be visible as company shareholder and director

Hope this helps
 
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#7
cangarooo said:
The suggestion to speak with an accountant is definitely key here.
Just be sure to get the right one.

My situation is "similar" to yours, with of course some exceptions:
- I do sell services to customers in Europe and US;
- I've a UK LTD with a non-resident status (I'm a EU citizen not resident in UK). For more info about UK LTD non-resident please refer to other posts in the Forum.
- I take advantage of paying zero corporate Taxes to UK and zero taxes in the country I live thanks to DTA
- I use a specific setup to not be visible as company shareholder and director

Hope this helps
Click to expand...
Why not giving your setup :)
 
#11
fifcbc said:
Hi there,
I'm going to sell my product (only in USA for the moment) with Amazon FBA/US fulfillment centers, and i'm wondering which option would be the best to pay the lowest taxes possible.

Knowing that i want to leave France to live either in Portugal or in London.

1/ Should I open an US LLC or a UK LLP/LTD ?

2/ Am I ETBUS or Non-ETBUS ? (some said i am non etbus cause amazon dont work only with me. But others said that i am etbus so I should pay federal tax in US and not in portugal/UK


What arrangement would be the best for me ?

Thank you!
Click to expand...
The definition of etbus could be ambiguous, but if you are worried, and your country has a tax treaty, you could file for tax treaty claims.
 
#13
cangarooo said:
The suggestion to speak with an accountant is definitely key here.
Just be sure to get the right one.

My situation is "similar" to yours, with of course some exceptions:
- I do sell services to customers in Europe and US;
- I've a UK LTD with a non-resident status (I'm a EU citizen not resident in UK). For more info about UK LTD non-resident please refer to other posts in the Forum.
- I take advantage of paying zero corporate Taxes to UK and zero taxes in the country I live thanks to DTA
- I use a specific setup to not be visible as company shareholder and director

Hope this helps
Click to expand...

@cangarooo I am also in a similar situation, EU citizen selling services to EU and US and others. My situation is described here in this post and I am trying to figure the best setup.

https://www.offshorecorptalk.com/th...cheme-where-to-incorporate.35501/#post-192365
If you could PM or post there I would apreciate it a lot, thanks!
 
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#15
cangarooo said:
The suggestion to speak with an accountant is definitely key here.
Just be sure to get the right one.

My situation is "similar" to yours, with of course some exceptions:
- I do sell services to customers in Europe and US;
- I've a UK LTD with a non-resident status (I'm a EU citizen not resident in UK). For more info about UK LTD non-resident please refer to other posts in the Forum.
- I take advantage of paying zero corporate Taxes to UK and zero taxes in the country I live thanks to DTA
- I use a specific setup to not be visible as company shareholder and director

Hope this helps
Click to expand...

Hi @cangarooo could you please share in pm the details? I'm in the same situation. Thanks a lot
 
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