Documented operations for an international LLC.
The Manager doesn't change your tax obligation. It performs and records the functions included in the mandate: signing certain contracts, resolutions, compliance tracking, and reconciled bookkeeping. That leaves a record of who did what and when — it does not by itself create economic substance, effective management, or a tax conclusion in your country.
Evaluate your situation See country-by-country mapThe question your tax authority is going to ask you
A freelancer in any country with a U.S. LLC has exactly the same problem.
"You have an LLC in the United States, but you live here, work from here, and collect from here. Who decides, who signs, and who runs that LLC's operations?"
That question is answered with documentation, not adjectives. If the contracts, decisions, and transactions aren't recorded anywhere, the answer has to be reconstructed from memory and scattered chats.
"The LLC has a designated Manager in the United States who, within the agreed mandate, signs certain contracts, runs compliance tracking, and maintains the books. Every covered action is recorded with a date in the Governance Ledger."
That doesn't guarantee any tax outcome, and it doesn't replace your local advisor. It's available documentation, not a conclusion.
What we deliver and what we don't promise
The Manager documents the operations included in the mandate. We don't sell tax outcomes.
What the Manager does
- A dated record of the actions performed from the U.S.
- Documented separation of functions: who proposes and who signs
- Signature of the contracts and resolutions covered by the mandate
- Registered Agent, business address, and banking coordination
- Professional bookkeeping synced with your bank
- Corporate Evidence Dossier ready for your tax attorney
What we don't promise
- That your tax authority will accept it
- That the LLC has "effective management" in the U.S.
- Economic substance: that depends on people, assets, risks, and real activity
- 0% tax in your country
- Tax outcomes in any jurisdiction
- Local tax advice — that's your attorney's job
What your advisor must review, depending on your country of residence
The documentation the Manager provides is the same in every country. What changes is what your local advisor has to analyze. We've grouped tax systems into three blocks.
Territorial system — The source of the income is the central question
In countries with territorial taxation, only locally sourced income is taxed. Source isn't decided by the LLC's country, the client's, or the bank's: what has to be reviewed is where the work is performed, who performs it, and which assets and people are involved. The Manager doesn't determine that source — it provides the record of the actions included in the mandate so your advisor can analyze it.
| Country | Local tax | What your advisor must review | What Manager documents |
|---|---|---|---|
| Paraguay | 10% IRP | How the DNIT characterizes the source of each income stream, the IRP applicable to your personal work, VAT, and the treatment of both retained earnings and distributions. | Contracts, reconciled bookkeeping, resolutions, and a dated record of the actions included in the mandate. |
| Panama | 25% | Whether the DGI treats the income as Panamanian-source based on where the service is actually performed. | Which actions are performed under the mandate, who signs them, and the date they were recorded. |
| Uruguay | 25% IRAE | The DGI's source criteria and whether your activity constitutes Uruguayan-source income. | Contracts, classified transactions, and recorded decisions. |
| Costa Rica | 30% | The current scope of the territorial criterion and any regulatory changes underway. | An organized, up-to-date corporate file. |
| Guatemala | 25% | Source rules and the formal obligations that apply to your activity. | A documentary record of the operations included. |
| Georgia | 1-15% | The tax-on-distribution model and how a distribution from the LLC is characterized. | Resolutions and transactions with documentary support and a date. |
| Hong Kong | 16.5% | The IRD's source criteria, based on where the profit-generating activity is carried out. | Which activities are performed under the mandate, and from where. |
| Malaysia | 24% | The current regime for remittances of foreign income and how it applies to your case. | Documentary separation between the LLC's transactions and personal ones. |
| Thailand | 20% | The rules on taxation of foreign remittances in force since 2024. | Traceability of the LLC's income and payments. |
Special regimes — The fit is determined by local law
These countries offer favorable tax regimes to attract residents. Each regime has its own requirements and its own way of characterizing a foreign entity. Your local advisor is the one who determines whether your operations fit; the Manager supplies the documentary file that analysis is based on.
| Country | Regime | What your advisor must review | What Manager documents |
|---|---|---|---|
| Portugal | NHR / IFICI | How the AT characterizes the LLC and whether the activity is attributed to the individual. | The LLC's contracts, resolutions, and bookkeeping. |
| Italy | Impatriati (70-90% exemption) | The regime's requirements and permanent-establishment risk in Italy. | A record of actions taken and decisions logged. |
| Cyprus | Non-dom (dividends exempt) | Characterization of the LLC and its distributions for non-dom purposes. | An organized corporate file. |
| Malta | Remittance basis | What counts as a remittance and how the LLC's income is characterized. | Traceability of income, payments, and distributions. |
| Andorra | 10% IS | Characterization of the entity and its income for Andorran corporate tax. | Documentation of the operations included in the mandate. |
| Greece | Non-dom (7% flat) | The regime's requirements and the characterization of the LLC before the AADE. | Documentary evidence available to your advisor. |
Worldwide income — Corporate documentation in the face of inquiries
In these countries you'll be taxed on your worldwide income no matter what. The LLC doesn't change your tax obligation, and neither does the Manager. What it provides is an orderly corporate file: contracts filed, transactions classified, and decisions dated — instead of having to reconstruct a whole year after the fact if an inquiry arrives.
| Country | Tax | What your advisor must review | What Manager documents |
|---|---|---|---|
| Spain | 19-47% | Tax residency, effective management, international tax transparency, and permanent establishment. The characterization of the LLC and its consequences are determined by the AEAT on the facts. | Contracts, resolutions, bookkeeping, and a dated record of the actions included. |
| Mexico | 30% ISR | REFIPRE / anti-deferral rules and the characterization of the LLC before the SAT. | Corporate file and traceability of transactions. |
| Colombia | 35% | ECE rules, effective place of management, and the DIAN's criteria. | A dated record of decisions and actions. |
| Argentina | 35% | International tax transparency and the anti-avoidance rules applicable to your case. | Documentation of operations and distributions. |
| Brazil | 27.5% | Taxation of foreign income and the Receita Federal's criteria. | Contracts, transactions, and resolutions, organized. |
| Germany | 25-45% | CFC rules (Hinzurechnungsbesteuerung) and the Finanzamt's criteria on foreign entities. | Documentary evidence available to your advisor. |
What the Manager performs and records
Each piece leaves a dated record of the actions included in the mandate. It's verifiable documentation, not a tax conclusion.
Governance Ledger
Chronological record of decisions, contracts, and resolutions. Full traceability for any audit. SHA-256 verification.
Operating Agreement
Bylaws that document the separation of functions and the limits of the mandate: what the Manager may sign and which decisions remain with the owner.
Contract signing
The Manager signs the commercial agreements covered by the mandate. The owner still signs wherever banks, authorities, personal guarantees, or documents outside the scope of the service require it.
Professional bookkeeping
Books synced with Mercury/Wise. Real financial data, not reconstructed after the fact.
IRS tax filing
Devil Club prepares and submits your annual Tax Filing to the IRS using bookkeeping data. Tax preparer with an IRS-registered PTIN.
Corporate Evidence Dossier
Complete dump of the available corporate documentation. Always up to date and organized for review by banks, advisors, or authorities where relevant.
Tax Presence Tracker
Automatic record of days per country based on your dashboard access. Passive evidence of geographic mobility and 183-day threshold alerts.
Even when it doesn't save you a dollar in taxes
Even in worldwide-income countries, where the Manager doesn't change your tax bill, having your operations documented is worth something on its own.
With operations documented
- Contracts and resolutions filed and findable
- Books reconciled against the bank, not reconstructed after the fact
- A dated history of decisions, with verifiable integrity
- Documentation ready when a bank or an advisor asks for context
- Tracking of the obligations included in your plan
Without operations documented
- Contracts scattered across email and chats
- Transactions still unclassified at year-end
- Decisions nobody recorded when they were made
- A year of activity you have to reconstruct from memory
- Obligations spotted late, or not at all
About documented operations and substance
Want to know what impact this has on your case?
The effect of substance depends on your country of residence, your business model, and your personal situation. Let's talk.
Book an evaluation See what Manager includes