Use Cases

Can I Open a US LLC While Living in Europe? (UK/DE/FR/IT/ES 2026 Guide)

Yes — and the EU-US tax treaty makes it more attractive than people realize. Country-by-country breakdown.

Published on 7 min readShare

Europeans opening US LLCs has tripled since 2022, driven by digital nomads, remote freelancers, and SaaS founders. The math works because EU residents have favorable US tax treaties.

Why Europeans choose US LLCs

  • Stripe + PayPal access: even Stripe-supported EU countries get rate-limited on certain industries (crypto, drop-shipping, supplements). A US LLC gets you the full Stripe US account.
  • USD invoicing: skip FX conversion losses (typically 1-3% of revenue).
  • Tax efficiency: pass-through LLC + EU country self-employment can be more tax efficient than EU corporation (depends on country).
  • Asset protection: US LLC charging order protection is stronger than most EU equivalents.

United Kingdom

  • HMRC treatment: HMRC treats US LLC as "transparent" (pass-through) for income tax. You declare LLC income on your personal Self Assessment (UK).
  • No double taxation: UK-US treaty prevents being taxed twice.
  • Watch out: UK requires you to register as self-employed in UK if active management is there. Your LLC income goes on your UK Self Assessment.
  • Recommendation: Wyoming LLC + your UK self-employment registration.

Germany

  • Treuhand vs Personengesellschaft: this is the only EU country where LLC tax classification is contested. Talk to a German Steuerberater familiar with US LLCs.
  • Most common treatment: US LLC = Personengesellschaft (partnership) → pass-through, you declare income personally.
  • Best path: Wyoming LLC + report income on German Einkommensteuer.
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France

  • Bénéfices Industriels et Commerciaux (BIC): LLC income classified as BIC, declared on your French tax return.
  • No CFC rules for individual owners under €2M revenue.
  • Best path: New Mexico LLC if you want lowest cost or Wyoming for privacy. Register as auto-entrepreneur OR EURL depending on revenue.

Italy

  • Italy treats US LLC as fiscally transparent.
  • Treaty: 0% withholding on royalties, 5-15% on dividends.
  • Watch out: Italian CFC rules apply if you own >50% and the LLC is in a low-tax jurisdiction. NM/WY are not "low-tax" in Italian CFC terms (no income tax doesn't trigger it for service businesses, only for passive income).
  • Best path: Wyoming LLC + Partita IVA Italian filing.

Spain

  • Atribución de rentas: Spain treats US LLC as fiscally transparent (income flows to you).
  • Tax: declare LLC income on IRPF (your personal tax return).
  • Watch out: if you're a tax resident of Spain, you owe Spanish income tax on worldwide income. The LLC doesn't shield you. It just provides US payment infrastructure.
  • Best path: New Mexico LLC + autonomo registration OR no Spanish business if you stay below threshold.

Netherlands, Portugal, Sweden

Similar pass-through treatment. NHR program in Portugal made LLCs attractive (but NHR is changing in 2026, so check your status).

What Europeans should NOT do

  • Skip your home-country tax registration thinking the LLC replaces it. It doesn't.
  • Pretend not to be tax-resident in your EU country. Tax residency follows where you live, not where your company is registered.
  • Open a Delaware C-Corp instead of an LLC unless you plan to raise from US VCs. Double taxation will kill you.

Get started with LLCora

Our Pro plan ($299) covers everything for EU residents. Premium adds a 1:1 call where we discuss your specific country's treatment. We also have country-specific guides: Spain, Germany, France, and more.

LLCora Editorial Team
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