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USA LLC vs Armenia LLC for a EU resident

Hi!

Just wonder which would you consider a better option for an EU resident doing 100% digital services with worldwide clients (mainly USA, EU and Australia clients).

Would you open an unipersonal (passthrough) United States LLC or an Armenia LLC ?

Thanks!

Somone has an Armenia LLC running? It's possible to make by distance?

As Armenia doesn't report your under CRS because they are not under CRS, would be useful to open an LLC there as non resident? Some advise?
 
Somone has an Armenia LLC running? It's possible to make by distance?

As Armenia doesn't report your under CRS because they are not under CRS, would be useful to open an LLC there as non resident? Some advise?
I'm running Armenian LLC right now. Your business can't have any expenses outside Armenia, otherwise you will have to pay 23% WHT on all outgoing payments. Other than this, you can apply for IT company status and pay no corporate taxes, just dividend tax 5% or so. It seems that you dont have to pay VAT for export of services (which can be your business model if I understood right). But IT status is not for everyone, you probably need to develop your own software

Setup can be done remotely but its very difficult to get bank account without personal visit. For card acquiring you will have to either use 2checkout and pay extremely high fees or you have to apply for merchant account in any of Armenian banks. For card processing you may need to have a real office address in Armenia where bank managers can go and visit.

It is preferrable that you become resident in Armenia. For that you only need to have a real business activity with real clients to show + 2k EUR or so for residency processing.
 
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Thank you @avalanche for quite detailed answer. About that:

- Armenian company cannot have euro account at any EMI like Transferwise, Revolut?
- Imposible to be resident in Armenia, because for European citizens (like France, Spain, Portugal...) it's not possible second residence in Armenia
- So only being a IT company in Armenia will be the best way to have only a 5% tax on dividend. I think good combination can be have a personal non-resident account at an Armenian Bank and pay yourself the dividends from the company to you personal account in there with the 5% tax. Is that right?
- You can invoice european/us citizens with the IT company without problems?
- Will Armenia o armenian bank report something to your own country?
- Your personal data is accessible from companies register of Armenia or similar? In Estonia, for example, is public...
- Being an IT company is enough to build an online guide in several languages or develop Joomla/Wordpress websites?

Many thanks in advance for your help on that
 
Thank you @avalanche for quite detailed answer. About that:

- Armenian company cannot have euro account at any EMI like Transferwise, Revolut?
No, most EMIs will not service you with Armenian company. You have to use local banks (which are very good but need some extra care)
- Imposible to be resident in Armenia, because for European citizens (like France, Spain, Portugal...) it's not possible second residence in Armenia
Thats weird, I didnt know. You will need residence permit at least (no need for tax residency) to maintain Armenian company. That is the most optimal way. Banks dont like random people who do all things totally remotely.
- So only being a IT company in Armenia will be the best way to have only a 5% tax on dividend. I think good combination can be have a personal non-resident account at an Armenian Bank and pay yourself the dividends from the company to you personal account in there with the 5% tax. Is that right?
Its possible yes. This money can be transferred anywhere else afterwards.
- You can invoice european/us citizens with the IT company without problems?
Easily. We are working only with EU clients right now + clients from Middle East are just fine. Get paid in USD, EUR, CHF or whatever currency you like
- Will Armenia o armenian bank report something to your own country?
I dont know. From what I understand, they dont do reporting even to their own government lol. Unless Armenian police has court order to access your bank account, there is bank secrecy in here.
- Your personal data is accessible from companies register of Armenia or similar? In Estonia, for example, is public...
No, even banks need your written permission to process your company data before opening an account. If I understood right, you need to be authorized to get such information from the government registry. No public data so far (but still be careful, I dont know all the details)
- Being an IT company is enough to build an online guide in several languages or develop Joomla/Wordpress websites?

Many thanks in advance for your help on that
From what I know, you need to either sell materials for education in IT fields OR you can develop and sell software licenses. Developing Joomla/Wordpress websites will be good enough for applying.

Note: if you register a normal company stating that it works in IT but you do not apply for this license within several months, you may forever lose the chance to apply for the license on a personal level. Open company and apply for this license immediately, do not wait (it was my mistake lol)
 
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Hello again @avalanche Many thanks for all the provided details. About all that you posted, only 2 doubts:

ABOUT "Easily. We are working only with EU clients right now + clients from Middle East are just fine. Get paid in USD, EUR, CHF or whatever currency you like"

- The armenian banks let you have account in EUR, USD and CHF with no problem? They don't use intermediate banks or similar to let the money enter the account? (I think this could be very expensive in that way).

- Banks there provide your company with merchant account to integrate to your website and checkout your clients directly in EUR or USD? (instead of AMD)

ABOUT "From what I know, you need to either sell materials for education in IT fields OR you can develop and sell software licenses"

- That license is easy to apply and cost-free?

- What do you think about AmeriaBank to manage merchant account for a company?

Many thanks mate!
 
Hello again @avalanche Many thanks for all the provided details. About all that you posted, only 2 doubts:

ABOUT "Easily. We are working only with EU clients right now + clients from Middle East are just fine. Get paid in USD, EUR, CHF or whatever currency you like"

- The armenian banks let you have account in EUR, USD and CHF with no problem? They don't use intermediate banks or similar to let the money enter the account? (I think this could be very expensive in that way).
There is no problem whatsoever but of course they use intermediary banks. We even use merchant account services with below 3% card processing fee (can process payments in EUR). We dont pay anything for receiving money via wire transfer. EUR arrives within 1 working day. CHF is very expensive though when you exchange it to something else or move it around.

It costs around 10-20 EUR to send outgoing wire transfer in EUR (depending on commission setting BEN, OUR, OUR-OUR). Transfers are approved quickly and without any issues.
- Banks there provide your company with merchant account to integrate to your website and checkout your clients directly in EUR or USD? (instead of AMD)
EUR, USD and AMD are all supported without any problem. We are processing over 30k EUR/mo without any questions whatsoever. Just dont fuckup with chargebacks and have legit business with full transparency and solid website. The only drawback, you will have to develop software for integrating their API gateway. Most of all, dont do shady of fishy activity and stay compliant
ABOUT "From what I know, you need to either sell materials for education in IT fields OR you can develop and sell software licenses"

- That license is easy to apply and cost-free?
It costs something but Im thinking budget around 2k EUR for setup of license and LLC with bank account should be enough. Might take around 1-2 months to get license, bank takes usually 3-7 working days.
- What do you think about AmeriaBank to manage merchant account for a company?
Its one of the most scrutinizing and strictest banks over here. They will ask you for details more than any other banks. But once you get an account with them, you can easily apply for any other bank and tell them you already have Ameria. They think like "oh these guys approved him, so he must be legit".

Almost any bank in Armenia has merchant account services. They all connect to ArmenianCard (ArCa) processing network which is centralized Visa/Mastercard gateway. Basically ArCa (central bank) is giving merchant services to banks and banks sell access to businesses
Many thanks mate!
 
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So grateful to know about that details. Are you armenian guy or european one? (I ask it because you told me about getting double nationallity).

You recommend me some incorporator for setting up the IT LLC?
 
So grateful to know about that details. Are you armenian guy or european one? (I ask it because you told me about getting double nationallity).

You recommend me some incorporator for setting up the IT LLC?
Neither armenian nor european. I didnt say about getting nationality or citizenship, I only mentioned residency. These are very different things. Not sure if I can mention incorporator while keeping it aligned with the rules of the forum
 
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No, most EMIs will not service you with Armenian company. You have to use local banks (which are very good but need some extra care)
do you still think they are good, what bank would take on a foreigner with a local company in Armenia?
 
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No, you are all wrong. My fingers are becoming sore from typing this over and over.
You cannot live and work in your high-tax country and just register a company in some other country and expect to pay that country’s taxes instead. If that was possible, everybody would be doing it. It would be the same as your government saying: “You know what, just decide how much tax you want to pay!”

I’m no expert on Spain, but I don’t think you can avoid the autonomo fees that way either. Because when everything is done from Spain, you must register a Spanish office for your US company and then it will be the same all over.
Unless you can avoid the fees with a SARL then you can’t avoid them with a US LLC or UK LLP or whatever structure. You’d need something more complex.

"Tax law often contains rules about how certain domestic entities are taxed – either as a separate legal entity or as fiscally transparent. Under the former approach, the entity itself would be subject to tax, whereas under the latter, the entity itself would not be taxed but the members of the entity would be subject to tax."

  • US limited liability companies (LLCs), S Corporations and other business entities regarded as partnerships or not liable to the US corporation tax, are treated as fiscally transparent


US Disregarded Entity is "Fiscally Transparent" in Spain, so no spanish registered office required as it's not a legal entity, however you would still need to declare Autonomo & pay the equivelant income tax.

US LLC for US banking, Armenian LLC for Armenian banking really answers the original question. You can ofcourse register a US LLC & then go live somewhere with lower tax rates like Bulgaria, or somewhere tax free as it remains a pass through entity.
 

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