Anyone forming abroad starts by comparing legal forms: LLC against Ltd, OÜ against Sp. z o.o. The eight forms GCS incorporates all have limited liability. They differ mainly in who stands beside you in the register and how they are taxed. The most flexible of them is the US LLC, our core product. Which form suits you depends above all on where you live and where you work from.
Where you decide determines the tax
A company is taxed where it is actually run. That is its place of management, the place where you take the day-to-day decisions. It also counts as a permanent establishment, a fixed place of business (section 10 AO).
For you this means: the legal form works where you live. If you work without a fixed residence or live in a country that does not tax this income, you use the US LLC with its full flexibility. If you want to run a company in the EU, you move to the country of registration. Residence, management and register then sit in the same place. More in the article Place of management.
In short: settle where you live and decide first, then choose the legal form.
Liability and number of shareholders: lean everywhere
All eight forms separate the company’s assets from your private assets. The Polish JDG and the Georgian sole trader with Small Business Status (a tax regime for small sole traders) are personally liable instead. They are alternatives, not part of this comparison.
All eight can be formed by one person alone, the standard case the GCS packages assume. Personal guarantees remain, as everywhere, your own matter.
In short: on liability and number of shareholders, the eight forms are much the same.
Statutory roles: who stands beside you in the register
Every jurisdiction requires an address, some also a person with a statutory function. Both are included in the GCS packages where the country requires them.
- USA: a registered agent, an address in the state of formation for official mail, plus an operating agreement (company agreement) and an EIN (US tax number). The LLC needs no local director.
- Cyprus and Malta: a registered office (the official seat address) and a company secretary for the register filings.
- Ireland: a registered office, an EEA-resident director and, with only one director, a separate secretary. Without an EEA-resident director, a section 137 bond (an insurance in favour of the register) replaces him (CRO).
- United Kingdom: a registered office, no secretary (GOV.UK). Directors and PSCs (persons with significant control) go through Companies House identity verification.
- Estonia: a registered address and a contact person while management sits abroad. Not needed if you live in Estonia.
- Poland and Georgia: a business address only.
The ongoing amounts are in the article What forming abroad costs.
In short: everyone needs an address, a statutory person only the USA, Cyprus, Malta, Ireland and Estonia.
Capital: minimum amounts that are not prices
Share capital is the starting money you give the company. In Poland it is PLN 5,000, in Estonia with one shareholder EUR 0.01. In Malta the registration fee follows the authorised capital: up to EUR 1,500 it starts at EUR 100 electronically. The local professional settles the amount for the other countries in the first conversation.
In short: minimum capital stays the company’s money and is a hurdle nowhere.
Tax model: transparent, corporation or tax on distribution
The third feature sets the method of calculation.
Transparent is the US single-member LLC (an LLC with one owner) unless it elects otherwise. The USA treat it as a disregarded entity: the profit counts as the owner’s profit (IRS). A foreign owner without US business activity therefore usually pays no US income tax. Taxation follows the owner’s residence. That makes the LLC a particularly good fit for entrepreneurs without a fixed tax residence and for entrepreneurs in countries that do not tax this income, such as the United Arab Emirates (UAE government portal).
Corporation with current tax: the company pays tax on its profit every year.
- Cyprus: 15% since 2026.
- Ireland: 12.5% on trading income (profit from the day-to-day business), 25% on non-trading income.
- United Kingdom: 19% up to GBP 50,000 profit, 25% from GBP 250,000.
- Malta: 35% with a refund after distribution, an arithmetical 5% on qualifying trading profits, or an optional final 15%.
- Poland (Sp. z o.o.): 19%, 9% for eligible small companies.
Tax on the distribution at shareholder level is added.
Tax only on distribution applies in Estonia (22/78 of the net distribution), Georgia (15%) and, by election, Poland under the Estonian CIT. Georgia also deducts 5% withholding tax on dividends at the moment of payment. Retained profits stay untaxed until they leave the company. The model works best when you live in the country of registration.
| Country · form | Liability | Statutory role beside you | Minimum capital | Tax model |
|---|---|---|---|---|
| USA · LLC | limited | registered agent | — | transparent (single-member), taxed at residence |
| Cyprus · Ltd | limited | registered office, secretary | — | corporation, 15% |
| Malta · Ltd | limited | registered office, secretary | — | corporation, 35% with refund or final 15% |
| Poland · Sp. z o.o. | limited | business address | PLN 5,000 | corporation, 19% / 9%, optional Estonian CIT |
| Georgia · LLC | limited | business address | — | tax on distribution, 15% |
| United Kingdom · Ltd | limited | registered office | — | corporation, 19% / 25% |
| Estonia · OÜ | limited | contact person if managed abroad | EUR 0.01 | tax on distribution, 22/78 |
| Ireland · Ltd | limited | EEA director, secretary, registered office | — | corporation, 12.5% / 25% |
As of September 2026. “—”: no amount in our country data. Company rates, not the shareholder’s overall burden.
In short: the legal form sets the method of calculation, residence sets the amount.
Germany, Austria, Switzerland
If you stay resident in Germany, Austria or Switzerland and run the company from there, the profits are taxed there. All three countries apply the same idea: what counts is where the company is actually managed (article 50 DBG, Fedlex).
If you move, clarify two points with your adviser first: exit tax on existing shareholdings and, for Germans, extended limited tax liability. After that you use the chosen form to its full advantage. For EU companies with German shareholders, the substance test, meaning real business on the ground, protects against CFC taxation.
In short: when your residence moves, the place of taxation moves with it.
Our recommendation
For location-independent entrepreneurs GCS recommends the US LLC. It is our core product and the most flexible form in this comparison: formed online, no presence required and usually no US income tax without US business activity. It fits particularly well without a fixed tax residence or with residence in a country that does not tax this income. Formation costs €1,800, basic administration from year two €1,200.
If you want to live in the EU and run a company there, move first and form in the same country. For an operating business with staff or its own software that is usually Cyprus with non-dom status (Cyprus residence model). The Ltd pays 15% corporate tax, and qualifying development profits fall under the IP box. Formation costs €4,500, basic administration from year two €1,800.
For a small digital business with EU residence, Estonia (OÜ, €650) fits, for the region Georgia (LLC, €1,800). Bulgaria offers 10% income tax, 10% corporate tax and 5% on dividends. Italy and Greece suit mainly passive foreign income. GCS plans and coordinates the route. The professional you engage directly makes the tax assessment.
What to do now
Write down where you want to live and work in twelve months. The choice is then usually quick; the country comparison puts the eight forms side by side with costs and obligations. In a first conversation we go through your profile and implement the form that fits through business formation abroad. The article After incorporation shows the annual calendar by country.