Side-by-side summary
The table compares a UK private limited company with a single-member US LLC owned by one non-US founder. Figures are official fees only; service fees such as a registered agent or registered office are extra.
| UK Ltd | US LLC (Wyoming, New Mexico, Delaware) | |
|---|---|---|
| Official formation fee | £100 online | WY $100 ($102.40 by card online); NM $50; DE $110 |
| Typical speed | Typically within 24 hours online | WY active on completion of online filing; DE paid expedite from 24 hours |
| Identity verification | Required for every director and PSC | No identity document filed with the state |
| Local address | UK registered office | Registered agent in the state |
| Yearly filings | Confirmation statement, accounts, CT600 | Form 5472 with pro forma 1120; state report or tax where the state has one |
| Yearly official fees | £50 confirmation statement | WY from $60; DE $400 LLC tax; NM none |
| Entity-level tax | Corporation Tax 19% to 25% | None for a disregarded LLC; income is the owner's |
| Consumption tax | VAT (UK-wide) | State sales tax, where nexus exists |
Formation cost and speed
The official fees are low on both sides. The UK charges £100 to incorporate online, per the Companies House fees list, and GOV.UK says online registration is typically within 24 hours.
In the US each state sets its own fee. Wyoming charges $100 for Articles of Organization (Wyoming fee schedule) plus a 2.4% card fee online, and the company is active as soon as the online filing completes. New Mexico charges $50 under NMSA 53-19-63. Delaware charges $110 with optional expedite from $50 for 24 hours, per its August 2026 fee schedule. Our LLC state fee comparison lists more states.
Formation is only the first step. A US LLC then needs an EIN from the IRS, which is free but for non-residents goes by fax, mail or the international phone line. A UK company is usually registered for Corporation Tax at the same time as incorporation, and HMRC posts the UTR to the registered office.
Identity verification vs no ID at formation
This is one of the biggest practical differences. Since 18 November 2025, every new UK director and person with significant control must verify their identity with Companies House before the company can be formed, as set out in when you need to verify your identity. A biometric passport from any country works with GOV.UK One Login, which is free. Only an Authorised Corporate Service Provider can verify on someone else's behalf.
US states do not ask for an identity document when you file. The Wyoming, New Mexico and Delaware formation documents do not even require member names. You will still show ID later: to the IRS as the responsible party on Form SS-4, and to any bank or payment provider. See our identity verification guide for the UK process.
Ongoing filings every year
UK Ltd
- Confirmation statement: at least every 12 months, £50 online, per Companies House guidance.
- Annual accounts: first accounts 21 months after incorporation, then 9 months after the year end. A dormant company still files.
- CT600 Company Tax Return: due 12 months after the accounting period ends, per Company Tax Returns. Late filing costs £200, then another £200 at 3 months, for returns due from 1 April 2026. Filing needs commercial software because HMRC's free service closed on 31 March 2026.
US LLC
- Form 5472 with a pro forma Form 1120: every year for a foreign-owned single-member LLC, even with no income, due 15 April (15 October with Form 7004). It cannot be e-filed; it goes by fax or mail. The penalty for not filing is $25,000, per the Form 5472 instructions. Our Form 5472 guide explains it.
- State report or tax: Wyoming's annual report is the greater of $60 or $0.0002 per dollar of Wyoming assets; Delaware LLCs pay an annual tax of $400 from the 2026 tax year, due 1 June, per Delaware's tax instructions; New Mexico has no LLC annual report.
- Registered agent: renewed each year.
- No BOI report: FinCEN's final rule of 14 August 2026 removed BOI reporting for all US-formed companies, including LLCs with non-US owners.
Tax basics at a high level
The two structures are taxed in very different ways. This section explains general rules only; where you live and where the work is done can change everything, so get advice on your own position.
UK Ltd. The company pays Corporation Tax on its profits: 19% up to £50,000, 25% above £250,000, with marginal relief in between, per Corporation Tax rates. Money you take out as salary or dividends may then be taxed in the UK, in your home country, or both, depending on your residence and any tax treaty.
US LLC. A single-member LLC is disregarded for US federal income tax by default, so its income is treated as the owner's. According to the IRS page on taxation of nonresident aliens, nonresidents are taxed on income effectively connected with a US trade or business (ECI) and on certain US-source income. A nonresident owner whose LLC earns foreign-source income that is not ECI may therefore owe no US income tax. The LLC still files Form 5472 every year. Whether your activity creates a US trade or business is a question for a licensed US tax professional.
No US tax does not mean no tax. Your home country may tax LLC profits as your personal income. Check local rules before choosing either structure.
Payment processor access
Stripe lists both the United States and the United Kingdom as supported countries on its global availability page, while Pakistan and Bangladesh are not listed and Nigeria appears only through Paystack. Either company can therefore apply for a Stripe account in its own country.
Stripe's requirements for another country are a legal entity registered in that country, a physical (not virtual) bank account there, a physical address there that is not a PO box, and government ID from any country. For a US account, Stripe also checks the EIN. Stripe reviews every application, so no provider can promise approval. Our payment account help covers the applications.
Banking
Banking depends more on where you live than on the company. Each provider publishes its own rules, and they change.
- US LLC: Mercury accepts non-US founders but lists prohibited countries that include Pakistan, Nigeria and Bangladesh; India and the UAE are not on that list. Wise Business asks US businesses for physical address proof and does not accept virtual addresses.
- UK Ltd: Tide accepts directors with an overseas home address but needs a UK mobile number and a UK app store account. Revolut Business asks UK companies to prove physical presence in the UK or EEA and the applicant to live in a supported country. Wise Business supports UK limited companies.
None of these providers guarantees an account, and neither do we. Our US LLC bank account guide goes deeper.
VAT vs sales tax
The UK has one national VAT; the US has state sales taxes and no national equivalent.
- UK VAT: registration is required once taxable turnover passes £90,000, per the VAT threshold notice. A UK company run entirely from abroad may be a non-established taxable person with no threshold at all; HMRC's manual at VATREG37150 says UK incorporation alone does not create a UK establishment. That point needs professional advice.
- US sales tax: each state sets its own economic nexus test. Wyoming, New Mexico and Florida use $100,000 of sales into the state; Texas uses $500,000; Delaware has no sales tax. Physical goods shipped to US customers are the usual trigger for registration, which our sales tax registration page covers.
Privacy
A UK company's directors, service addresses, people with significant control and filed accounts are public on the Companies House register, though your home address can stay private. Wyoming, New Mexico and Delaware do not require member or manager names on the LLC formation document, which names the registered agent instead. Texas is different: its formation form lists the managers, or the members if there are no managers, and these are public. With BOI reporting removed for US companies, an LLC in the first three states can be formed without the owner's name appearing in the state filing.
Which suits which scenario
| Your situation | Often a better fit |
|---|---|
| Selling mainly to US customers, or needing a US Stripe account | US LLC |
| Selling mainly to UK or European customers | UK Ltd |
| Wanting to keep ownership off public records | US LLC (WY, NM or DE) |
| UK clients or platforms that ask you to contract through a UK company | UK Ltd |
| Freelancer or agency with foreign-source income and low annual costs in mind | US LLC in New Mexico or Wyoming |
| Planning to raise venture capital in the US | Neither; see our LLC vs C corp comparison |
Answer a few questions in our US LLC or UK Ltd quiz for a starting point. Some founders form both: a US LLC for US sales and a UK company for UK and European clients. Budget for two sets of annual filings if you do.
For a UK company, our UK Ltd starter covers formation, the registered office, the service address, Corporation Tax registration and the first confirmation statement. For the US, the starter below covers formation, EIN, registered agent, operating agreement and the first Form 5472.
Sources
- GOV.UK: Companies House fees
- GOV.UK: Register your company
- GOV.UK: When you need to verify your identity for Companies House
- GOV.UK: Filing your company's confirmation statement
- GOV.UK: Company Tax Returns
- GOV.UK: Corporation Tax rates
- GOV.UK: Increasing the VAT registration threshold
- HMRC: VAT Registration Manual VATREG37150
- Wyoming Secretary of State: Business fees
- New Mexico Statutes: 53-19-63 fees
- Delaware Division of Corporations: Fee schedule (August 2026)
- Delaware Division of Corporations: LLC and partnership tax instructions
- IRS: Instructions for Form 5472
- IRS: Taxation of nonresident aliens
- Federal Register: BOI Reporting Requirement Revision (91 FR 52508)
- Stripe: Global availability
- Stripe Support: Requirements to open a Stripe account in another country
- Mercury: Prohibited countries
- Wise: Verify your US business
- Tide: Can I apply from abroad?
- Revolut Business: Eligible countries of residence
- Texas Comptroller: Remote sellers
Fees, deadlines and rules on this page were last checked on 27 September 2026.