US LLC and UK Ltd are the two most popular entities for non-resident SaaS founders. They solve overlapping problems differently. Here is a decision framework.
Side by side
| Feature | US LLC (Wyoming) | UK Ltd |
|---|---|---|
| Formation cost | $100 + $99 RA = $199 | £12 + accounting setup ~£200 |
| Annual cost | $159 | £13 Companies House + £600-1,500 accountant |
| Tax | Pass-through | 19-25% corporate tax |
| Banking | Mercury, Stripe USD | UK high street + Wise |
| Stripe access | Stripe US (lower fees) | Stripe UK (slightly higher fees) |
| Privacy | Anonymous in WY | Public director listing |
| Compliance | Form 5472 yearly | Full UK accounts annually |
| VAT | Not applicable | Required at £90K+ revenue |
When US LLC wins
- Majority US customers: Stripe US has slightly lower fees, faster payouts.
- You don't want corporate tax: pass-through means you only pay your home country tax.
- You want privacy: Wyoming LLCs don't list owners publicly.
- You sell digital products (no VAT complexity).
When UK Ltd wins
- Majority UK/EU customers: easier VAT collection, EU banking integration.
- Building a venture-backable SaaS: UK Ltd is more familiar to European VCs than US LLC.
- Want to keep profits in the company to reinvest (US LLC pass-through means profits flow to you personally).
- You want to look like a "real" company for enterprise B2B sales (some EU enterprise buyers don't recognize US LLC as fully credible).
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Hybrid: doing both
Some founders run a UK Ltd as the holding company and a US LLC as a payment subsidiary. This works but adds complexity:
- UK Ltd owns 100% of US LLC
- US LLC processes US customer payments and remits to UK Ltd
- UK Ltd pays corporate tax in UK on the consolidated income
Don't do this unless you're past $300K revenue or have a UK accountant who's done it before.
Tax math example (Spanish freelancer with $100K SaaS revenue)
US LLC route:
- LLC pays $0 federal tax (pass-through)
- You pay Spanish IRPF on full $100K → ~25-37% depending on brackets
- Total tax: ~$25K-$37K
UK Ltd route:
- UK Ltd pays 19% on $100K = $19K
- Remaining $81K stays in company OR is paid as dividend
- If dividend, you pay Spanish IRPF on dividend (with treaty relief)
- Total tax: variable, often $25K-$32K
- Bonus: profits in company can be reinvested without immediate personal tax
The UK Ltd route can save 5-10% IF you reinvest. If you take everything as salary/dividend, US LLC is usually equivalent or better.
What we see at LLCora
90% of SaaS founders choose US LLC because:
- Cheaper to maintain ($159 vs $600-1,500/year accountant)
- Simpler tax (no UK accounting standards)
- Stripe US is what most SaaS uses anyway
The 10% who go UK Ltd are usually building enterprise SaaS targeting EU/UK customers with VAT complexity, or planning UK VC funding.
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