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US LLCs and a country without VAT: what the US system offers European founders

The United States runs on different plumbing: no VAT anywhere in the system, a flat 21% federal corporate tax, and an entity, the LLC, that by default pays no tax itself and passes everything to its owner. Each of those differences creates an opening for a European business, and each has a sharp edge.

Published 2026-07-16Last reviewed 2026-07-16

Key facts

ItemRule
VATNone — state retail sales taxes instead (0–11%+)
Sales-tax duty for a remote sellerEconomic nexus — commonly $100,000 of in-state sales
Federal corporate tax (C corporation)21% flat
LLC default taxationPass-through — no entity-level federal tax
S corporationNot available to non-resident aliens
Withholding on US-source payments to non-residents30%, often reduced by treaty

[1][2][3][5]

Selling into a country with no VAT

Selling B2C into the EU means charging destination-country VAT from €10,000 of cross-border turnover, via the OSS return. Selling into the US, the same business faces no federal consumption tax at all: only state retail sales taxes, which apply once economic nexus is crossed, commonly at $100,000 of sales into that state (the standard set by South Dakota v. Wayfair). Sales taxes are also single-stage: they hit the final retail sale, and B2B purchases for resale are exempt by certificate. For a European seller of modest US volume, the practical consumption-tax burden is often zero.[3][4][8]

The pass-through LLC

An LLC is taxed as a pass-through by default: the entity files information returns but pays no federal income tax; profit lands directly on the owner. For a non-resident owner with no US trade or business (no US office, staff or dependent agents) that can mean no US federal income tax on the LLC’s profits at all. The catch is built into the same sentence: the profit is then taxable where the owner is resident, at that country’s personal or corporate rates. The LLC moves the taxing right; it does not abolish it.[1]

The S corporation, the other pass-through, is closed to this audience: its shareholders must be US individuals or certain trusts, with non-resident aliens explicitly excluded. And US-source passive income (dividends, interest, royalties) paid to non-residents is withheld at 30%, reduced only by treaty.[1][5]

The catch

Three caveats. First, home-country tax: a Lithuanian, German or French resident owning a transparent LLC owes home tax on its profits as they arise, and some countries treat the LLC as opaque, creating messy double-taxation puzzles. Second, US connections: an office, inventory in US warehouses, or dependent agents create effectively connected income, and with it US filing and tax. Third, states: formation-state fees (Delaware’s $300 flat LLC tax), sales-tax registrations state by state, and state income taxes where nexus arises. The structure is clean only while the facts stay clean.[7][5]

Frequently asked questions

Does a US LLC mean paying no tax anywhere?

No. A pass-through LLC moves the tax to its owner. A European resident owner owes home-country tax on the LLC’s profit; the US side is quiet only while the business has no US trade or business.

When must a European seller register for US sales tax?

State by state, once economic nexus is crossed — commonly $100,000 of sales into the state, the threshold upheld in South Dakota v. Wayfair (2018). A handful of states levy no general sales tax at all.

Do US companies still report beneficial owners?

Since March 2025, FinCEN requires beneficial ownership reports only from foreign companies registered to do business in the US — US-formed LLCs and corporations are exempt.

Cross-border outcomes depend on tax residency, controlled-foreign-company rules and real substance — a structure on paper is not enough. See the disclaimer below.

Sources

Numbered references cited throughout this article. Laws link to consolidated texts in the official register.

  1. S corporationsIRS · authority
  2. 26 U.S. Code §11 — tax imposed on corporationsgovinfo.gov (U.S. GPO) · law
  3. South Dakota v. Wayfair, 585 U.S. 162 (2018)Supreme Court of the United States · law
  4. Sales & use taxSouth Dakota Department of Revenue · authority
  5. Withholding on payments to foreign persons (NRA withholding)IRS · authority
  6. Beneficial ownership information reportingFinCEN (U.S. Treasury) · register
  7. Annual report & franchise taxDelaware Division of Corporations · register
  8. VAT One Stop Shop (OSS) rulesEuropean Commission · eu

This guide is general information, not tax or legal advice. Rates and deadlines change — always verify against the linked laws and official sources, or ask a licensed advisor, before acting.