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Territorial residency + LLC

Your tax framework is already territorial.
Now you need the structure.

You live in a country that generally taxes only local-source income. Your U.S. LLC, properly configured as a pass-through with no ECI or effective presence, typically generates no U.S. federal tax. In the best case, your combined burden can approach zero — always subject to your specific tax residency and to documented governance. Local tax advice recommended.

How the combination works

If your tax residency is territorial, foreign-source income usually falls outside local taxation. A U.S. LLC treated as a disregarded entity, with no ECI or effective presence, typically generates no U.S. federal tax. Combined, the tax burden can drop significantly — the actual outcome depends on each case and must be validated with local advice.

🌐 Your clients

They pay your LLC in USD

🇺🇸 Your LLC (USA)

Invoices, collects, operates
No federal tax if there's no ECI

🏠 You (territorial)

Foreign-source income
Usually outside the local tax base

The LLC alone isn't enough

Having the EIN and Mercury account is 20%. The other 80% is proving your LLC has real management, economic substance, and clean compliance. Without that, any audit — local or from the IRS — collapses your structure.

📋

Mandatory tax filing

Even if you owe no tax, the IRS requires Form 5472 + pro forma 1120 every year. Failing to file = minimum penalty of $25,000.

🏛️

Corporate substance

Your local tax authority can question where your LLC is actually managed. Without evidence of effective management in the U.S., it gets reclassified as a domestic company.

📒

Audited bookkeeping

Without bookkeeping kept to IRS standards, you can't prove income is foreign-source to your own tax authority.

🛡️

Documented governance

Every corporate decision must be logged with date, context, and outcome. Without a ledger, your LLC is a legally empty shell.

Manager: everything your LLC needs to actually run

Not a formation service — an ongoing operations ecosystem. While you focus on your business, we make sure your LLC has real substance, clean compliance, and bulletproof documentation.

  • Governance Ledger — Immutable record of corporate decisions with timestamp and blockchain anchoring (OpenTimestamps).
  • Monthly bookkeeping — Accounting integrated with Mercury, Stripe, and Wise. Automatic P&L, IRS-style categorization.
  • Core IRS filing included — Form 5472 + pro forma 1120 filed every year with the IRS. If your case triggers FBAR or BEA, we flag it separately and handle it without conflating it with BOIR.
  • Corporate Evidence Dossier — Documentary compilation of real U.S. activity. Your paper trail for any inquiry.
  • Bulletproof Operating Agreement — Tailored to your activity, with asset-protection clauses.
  • Contract signing — NDA, Service Agreement, Independent Contractor. PKCS#7 + RFC 3161 + OTS signing logged in the Ledger.
  • Lucy — your business AI — Monthly, quarterly, and annual analysis with concrete proposals based on your real data.
  • Public API — Connect your LLC to your stack: query bookkeeping, ledger, documents, and reports programmatically.

$3,600/year

All included. No surprises. No hidden extras.

Where this combination works from

If your country has a territorial regime (taxes only local income), a U.S. LLC with Manager is the perfect complement. Main options:

🇵🇾 Paraguay 🇮🇩 Indonesia 🇵🇦 Panama 🇨🇷 Costa Rica 🇬🇪 Georgia 🇲🇾 Malaysia 🇹🇭 Thailand 🇵🇭 Philippines 🇦🇪 United Arab Emirates 🇺🇾 Uruguay 🇬🇹 Guatemala 🇳🇮 Nicaragua 🇭🇳 Honduras 🇧🇿 Belize 🇭🇰 Hong Kong 🇸🇬 Singapore 🇲🇹 Malta

⚠️ Every country has nuances. The free initial consultation confirms whether your specific situation fits.

The 4 most common destinations

Not all territorial regimes work the same. These are the ones most Devil Club clients use, with their key conditions.

🇵🇾

Paraguay

Foreign income: usually exempt. 10% IRP on Paraguayan personal income.

Residency: 48h of in-person paperwork + notarized power of attorney. Maintenance: one visit per year keeps your status. Banking: Itaú, Banco Continental, Sudameris — all accept non-residents with a RUC.

Treaty with Spain (2024): yes. Preferential treatment for Paraguayan tax residents with demonstrable substance.
🇵🇦

Panama

Foreign income: typically out of scope. Local income: progressive up to 25%.

Residency: Retirement Visa (>$1,000/month verifiable) or Friendly Nations (18 listed countries, requires bank deposit or employment contract). Banking: Multibank, Banistmo — stricter due diligence. Maintenance: a visit every 2 years is enough.

Watch out: CFC rules (2019) may apply if your LLC is treated as a PFIC. Manager + documented governance protect this flank.
🇬🇪

Georgia

Foreign income: can stay out of scope if not remitted. Individual Entrepreneur "Small Business Status" 1% on local revenue (up to 500k GEL ≈ $185k).

Residency: 183 physical days or HNWI fast-track. Banking: TBC and Bank of Georgia — accept non-residents with work/investor visa. Maintenance: hit 183 days each fiscal year.

Competitive tax destination but logistically demanding (language, distance). The IE 1% regime is for local income, not your LLC's revenue.
🇦🇪

United Arab Emirates

Personal income: no general income tax. 9% Corporate Tax in effect for fiscal years starting June 2023; how a U.S. LLC fits depends on residency, permanent establishment, and where the business is actually managed.

Residency: Golden Visa (10 years, $545k investment) or Freelance Visa (6 months, from $3k). Banking: Emirates NBD, Mashreq — strict on AML. Maintenance: visa renewal every 2–10 years depending on type.

UAE Corporate Tax: a disregarded LLC stays out of scope only when it's not reframed as local nexus, permanent establishment, or effective management in the UAE. Manager documents U.S. substance, but the final analysis is case by case.

ℹ️ Other viable destinations: Costa Rica, Indonesia, Malaysia, Philippines, Uruguay, Hong Kong, Singapore, Malta. Key differences for each in the initial consultation.

How much you save with this structure

Compare what you'd pay as a self-employed worker in Spain vs running an LLC + territorial residency. Drag the slider to see the impact based on your revenue.

$20k $80,000 $500k

🇪🇸 Self-employed Spain

$28,800

IRPF + Social Security + lost VAT

IRPF (~36%)$28,800
Self-employment fee$5,400
Total tax burden$34,200

🌍 LLC + Territorial

$4,100

Total cost of running your LLC

Manager annual$3,600
U.S. taxes$0
Local taxes$0
Total$4,100

Estimated annual savings

$30,700

Over 3 years: $92,100

Basic LLC vs LLC with Manager

Most services hand you the EIN and disappear. See what happens when the LLC has real governance.

Basic LLC LLC + Manager
LLC formation + EIN
Mercury account
Registered Agent
Tax Filing (5472+1120)✘ extra✔ included
Monthly bookkeeping
Governance Ledger
Corporate Evidence Dossier
Custom OA✘ generic✔ bulletproof
Contract signing
Lucy (AI)
Public API
Under auditVulnerableBulletproof

Why it works

0%

U.S. federal tax for disregarded LLCs

$25k

Minimum IRS penalty for failing to file 5472

78+

Active LLCs managed by Devil Club

17

Compatible territorial countries

Disclaimer and official sources

Devil Club is not a licensed tax advisory firm and does not replace a lawyer/accountant in your jurisdiction. This page is educational: before deciding on a residency change or international structure, consult a local professional.

  • Paraguay (SET): set.gov.py — territorial regime, IRP, and residency.
  • Panama (DGI): dgi.mef.gob.pa — territorial income and non-domiciled status.
  • Georgia (Revenue Service): rs.ge — High Net Worth Individual and territorial regime.
  • UAE (Federal Tax Authority): tax.gov.ae — corporate tax and residency.
  • IRS (U.S.): irs.gov — tax treatment of disregarded LLCs, Form 5472 and 1120.
  • OECD (model tax treaty): oecd.org/tax — tie-breaker rules and double-taxation treaties.
Frequently asked questions
About the territorial calculator
A territorial tax system taxes only income generated inside the country. If you live in a territorial country (Paraguay, Panama, Georgia, etc.), foreign-source income — like your U.S. LLC's — generally isn't taxed in your country of residence. The calculator helps you estimate the impact on your situation.
No. The calculator estimates the impact of the territorial system on your situation, but the final tax obligation depends on additional factors: U.S. nexus, type of activity, bilateral treaties, and your personal profile. Always cross-check with a local advisor.
A change of tax residency takes effect from the date it's formalized in the new country (and you deregister in the old one). The calculator lets you adjust the residency period to estimate the partial-year impact during the transition.
No. Both have territorial systems, but with important differences in residency requirements, types of income affected, and treaties signed. The calculator differentiates between them and applies the specific parameters of each jurisdiction.
It's a quick-estimate tool, not a full tax plan. For serious planning around a residency change or international structure, the calculator's result is a good starting point, but you must complement it with professional advice.

The structure your territorial residency needs

Book a free video call. We'll walk you through how it works for your specific country in 20 minutes.

Recibe la guia y estrategias para tu LLC

v1.0.0 · local