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  • Form of entity

    Corporation (Sociedad Anónima or SA)

    Separate and distinct legal entity. Admits a minimum of two shareholders. Managed by a board of directors who are elected by the stockholders of the corporation.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Separate and distinct legal entity. Admits exclusively one shareholder. SAUs are not allowed to be incorporated or wholly owned by SAUs. Managed by a board of directors who are elected by the only stockholder of the corporation.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Separate and distinct legal entity. Admits one or more shareholders. Managed by a board of directors who are elected by the stockholders. There is an established form of bylaws and public notice that, if used, shall enable the registration of the SAS within 24 hours in the City of Buenos Aires. This new corporate type aims to be more agile and economic alternative, both in its incorporation and in the administration and management. Its incorporation and development are entirely digital.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    Separate and distinct legal entity. Admits a minimum of 2 members and a maximum of 50. Managed by a single manager or several managers with full powers who may act individually, or by a Board of Managers acting by majority, appointed by the members.

  • Entity set up

    Corporation (Sociedad Anónima or SA)

    • Two or more shareholders
    • The local management is in charge of a board of directors, which may have at least one member, no maximum number (at least three directors and one alternative director in case the company's capital stock exceeds ARS$50 million). Directors shall last between one and three years in office, as provided in the bylaws. They may be reelected. The majority of the board of directors must be composed of Argentine residents
    • The president of the board is the legal representative of the company
    • Statutory auditor is optional. Mandatory if capital stock exceeds ARS$50 million
    • Typical charter document: bylaws
    • Corporate Books: stock ledger, shareholders' meeting minutes, board of directors' meeting minutes and attendance records book
    • Should cash be paid out as consideration for the stock; only 25% needs to be paid up upfront, and the balance is paid within two years after that. When considerations for the stock are contributions in kind, the stock must be fully paid off at the time of subscription of the shares

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    • Only one shareholder
    • The local management is in charge of a board of directors, which may have at least one member, no maximum number (at least three directors and one alternative director in case the company's capital stock exceeds ARS$50 million). Directors shall last between one and three years in office, as provided in the bylaws. They may be reelected. The majority of the board of directors must be composed of Argentine residents
    • The president of the board is the legal representative of the company
    • Permanent control by government
    • Statutory auditor is mandatory (at least one regular and one alternate statutory auditor)
    • Typical charter document: bylaws
    • Corporate books: stock ledger, shareholders' meeting minutes, board of directors' meeting minutes and attendance records book
    • Capital stock shall be fully paid up upon execution of bylaws
    • SAUs are not allowed to be incorporated or wholly owned by another SAU

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    • One or more shareholders
    • The managers must be individuals, who may be appointed for an indefinite period. At least one director needs to be an Argentinean resident (provided that the Argentinian resident director is the legal representative of the company)
    • Statutory auditor is optional
    • Corporate books: carried by electronic means (stock ledger, minutes and attendance records book)
    • Should cash be paid out as consideration for the stock; only 25% needs to be paid up upfront, and the balance is paid within two years after that. When considerations for the stock are contributions in kind, the stock must be fully paid off at the time of subscription of the shares

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    • Two or more members
    • The local management is in charge of single or several managers with full powers who may act individually, or a board of managers acting by majority. Managers may be appointed for an indefinite term. The majority of the board of managers must be composed of Argentine residents
    • The legal representative of the company can be a single manager. All managers or a president of the board of managers are entitled with full powers
    • Statutory auditor is optional. Mandatory if capital stock exceeds ARS$10 million (at least one regular and one alternate member)
    • Typical charter document: bylaws
    • Corporate books: minutes
    • Should cash be paid out as consideration for the stock; only 25% needs to be paid up upfront, and the balance is paid within two years after that. When considerations for the stock are contributions in kind, the stock must be fully paid off at the time of subscription of the shares.
  • Minimum capital requirement

    Corporation (Sociedad Anónima or SA)

    Minimum capital of SA is ARS$100,000.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Minimum capital of SAU is ARS$100,000.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Minimum capital of SAS shall be twice the national minimum vital and mobile wage established at the time of its incorporation (as of March 2019: ARS$23,800).

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    No minimum capital requirement.

  • Legal liability

    Corporation (Sociedad Anónima or SA)

    Directors must act honestly and in good faith in best interests of the company. Directors can be held personally liable to the company, shareholders and third parties if they fail to comply with their general legal duties or specific duties contained in Argentine Law 19,550.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Directors must act honestly and in good faith in best interests of the company. Directors can be held personally liable to the company, shareholders and third parties if they fail to comply with their general legal duties or specific duties contained in Argentine Law 19,550.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Liability of directors of a corporation under Law 19,550 is applicable to SAS managers. In addition, individuals who are not managers or legal representatives of an SAS, or legal persons acting as managers, are liable in the same way as managers, and their liability will be extended to the acts in which they did not intervene but which they habitually performed.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    In case of SRLs, when articles allow distribution of management powers among individual members of the board of managers, board's liability depends on the individual performance of each manager.

  • Tax presence

    Sociedad Anónima (Corporation) and SRL (LLC)

    An S.A., same as an SRL (LLC), is considered an Argentine resident for tax purposes and is obligated to pay taxes on income obtained worldwide, whether earned within Argentina or abroad. An S.A. may take the sums effectively paid abroad for analogous taxes, for activities carried out abroad as a payment for taxes (within certain limits).

  • Incorporation process

    Corporation (Sociedad Anónima or SA)

    File bylaws for registration with the Public Registry. Starting from April 4, 2018, an "urgent" registration process may be followed to obtain the company's registration and its tax ID within 24 hours, in case no observations are made by the Public Registry in the City of Buenos Aires.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    File bylaws for registration with the Public Registry. Starting from April 4, 2018, an "urgent" registration process may be followed to obtain the company's registration and its tax ID within 24 hours, in case no observations are made by the Public Registry in the City of Buenos Aires.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    File bylaws for registration with the Public Registry. There is an established form of bylaws and public notice that, if used, shall enable the registration of the SAS within 24 hours through digital means in the City of Buenos Aires.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    File bylaws for registration with the Public Registry. An "urgent" registration process may be followed to obtain the company's registration, its tax ID and corporate books within 24 hours, in case no observations are made by the Public Registry in the City of Buenos Aires.

  • Business recognition

    Corporation (Sociedad Anónima or SA)

    Well regarded and widely used.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    This new corporate type was introduced in Argentina in August 2016 pursuant the Argentine Civil and Commercial Code modification and is beginning to be used.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    This new corporate type aims to be more agile and economic alternative, both in its incorporation and in administration and management. Its incorporation and development will entirely be in digital form.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    Well regarded and widely used. This is the type of company usually preferred by foreign shareholders due to tax purposes.

  • Shareholder meeting requirements

    Corporation (Sociedad Anónima or SA)

    Required to hold annual meeting of shareholders to approve the financial statements of the company.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Required to hold annual meeting of shareholders to approve financial statements of the company.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Required to hold annual meeting of shareholders to approve financial statements of the company.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    Required to hold annual meeting of members to approve financial statements of the company.

  • Board of director meeting requirements

    Corporation (Sociedad Anónima or SA)

    The board shall meet at least once every three months.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Periodical meetings of the board are not required.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Periodical meetings of the board are not required.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    Periodical meetings of managers are not required.

  • Annual company tax returns

    All corporations must annually file tax returns with federal and state tax authorities.

  • Business registration filing requirements

    Corporation (Sociedad Anónima or SA)

    Initial registration is required, as well as annual filings (financial statements of the company before the Public Registry and the Tax Authority). Every appointment or resignation of directors, change of domicile or bylaws' amendments must be filed with the Public Registry for registration.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Initial registration is required, as well as annual filings (financial statements of the company before the Public Registry and the Tax Authority). Every appointment or resignation of directors, change of domicile or bylaws' amendments must be filed with the Public Registry for registration.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Initial registration is required. SAS doesn't file its financial statements with the Public Registry, but these documents must be filed with the Tax Authority. Every appointment or resignation of directors, change of domicile or bylaws' amendments must be filed with the Public Registry for registration.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    Initial registration is required. Only SRLs which capital stock exceeds ARS$50 million shall file their annual financial statements with the Public Registry. However, all SRLs must file their fincancial statements with the tax authorities.

  • Business expansion

    Corporation (Sociedad Anónima or SA)

    No need to change as business expands.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    If the number of shareholders exceeds one, the SAU must convert to an SA or SAS.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    No need to change as business expands.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    If the number of members exceeds 50, the SRL must convert to an SA or SAS.

  • Exit strategy

    Any corporate type shall file dissolution documents with the Public Registry.

  • Annual corporate maintenance requirements

    Corporations and single-shareholders corporations must pay annual fee to the Public Registry.

  • Director / officer requirements

    Not applicable for this jurisdiction.

  • Local corporate secretary requirement

    Not applicable for this jurisdiction.

  • Local legal or admin representative requirement

    Not applicable for this jurisdiction.

  • Local office lease requirement

    In some circumstances, the Tax Authority requires evidence of the declared domicile.

  • Other physical presence requirements

    Not applicable for this jurisdiction.

  • Sufficiency of virtual office

    Not applicable for this jurisdiction.

  • Provision of local registered address by law firm or third-party service provider

    A company must provide its registered address. In certain circumstances, a law firm office can provide the registered address until the local entity hires an office. In this case, the company is requested to move its registered office to its new location.

  • Provision of local director or corporate secretary by law firm or third-party service provider

    A company shall provide a local director. In certain circumstances, a law firm may provide a local director service at a monthly rate.

  • Nationality or residency requirements for shareholders, directors and officers

    Corporation (Sociedad Anónima or SA)

    Majority of members of the board need to be Argentinean residents.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Majority of the members of the board need to be Argentinean residents.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    At least one director needs to be Argentinean resident (provided that the Argentinean resident director is the legal representative of the company).

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    Majority of the members of the board need to be Argentinean residents.

  • Restrictions regarding appointment of nominee shareholders or directors

    Not applicable for this jurisdiction.

  • Summary of director's, officer's and shareholder's authority and limitations thereof

    Not applicable for this jurisdiction.

  • Public disclosure of identity of directors, officers and shareholders

    Not applicable for this jurisdiction.

  • Minimum and maximum number of directors and shareholders

    Corporation (Sociedad Anónima or SA)

    • Two or more shareholders
    • Board of directors, which must have at least one member, no maximum number requirement (at least three directors and one alternative director in case the company's capital stock exceeds ARS$50 million)

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    • One shareholder
    • Board of directors, which must have at least one member, no maximum number requirement (at least three directors and one alternative director in case the company's capital stock exceeds ARS$50 million)

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    • One or more shareholders
    • The managers must be individuals, who can be appointed for an indefinite period

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    • Two or more members (within a maximum of 50 members)
    • The local management is maintained by a single manager, several managers with full powers who may act individually, or a board of managers acting by majority. Managers may be appointed for an indefinite term
  • Minimum number of shareholders required

    Corporation (Sociedad Anónima or SA)

    At least two or more shareholders.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    Only one shareholder is admitted.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    At least one shareholder.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    At least two or more members.

  • Removal of directors or officers

    Removal of directors or managers shall be approved by the shareholders meeting and then registered in the Public Registry.

  • Required and optional officers

    Not applicable for this jurisdiction.

  • Board meeting requirements

    Not applicable for this jurisdiction.

  • Quorum requirements for shareholder and board meetings

    Corporation (Sociedad Anónima or SA)

    The Board makes decisions by a simple majority of directors present at the relevant meeting, with a quorum of an absolute majority of total number of directors, unless the company's articles provide for a higher quorum and majority.

    In case of annual or regular shareholders' meetings, the required quorum shall be constituted by shareholders representing the majority of the voting shares. If quorum is not reached, the meeting can be held at a second call. In this case, the meeting is duly constituted with any number of shareholders present. On the other hand, special meetings require the presence of shareholders representing 60% of the voting shares, unless the articles provide for a higher quorum. If quorum is not reached, the meeting can be held at a second call. In this case, the meeting is duly constituted with the presence of shareholders representing 30% of the voting shares, unless the articles provide otherwise.

    Single-Shareholder Corporation (Sociedad Anónima Unipersonal or SAU)

    The board makes decisions by a simple majority of directors present at the relevant meeting, with a quorum of an absolute majority of total number of directors, unless the company's articles provide for a higher quorum and majority.

    In the case of shareholders' meeting, quorum is reached if at least one shareholder of the company is present.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    Meetings may be held physically or through digital means (video or teleconference). Managers and members may call themselves to hold deliberations, with no need of prior notice. The management body's resolutions are valid as long as all members attend, and the majority as stated in the bylaws approve the agenda. Member's resolutions will be valid, provided that all partners attend and the agenda is passed unanimously.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    The board makes decisions by a simple majority of the managers present at the relevant meeting, with a quorum of an absolute majority of total number of directors, unless the company's articles provide for a higher quorum and majority.

    In case of annual or regular members' meetings, required quorum is constituted by the shareholders representing the majority of the voting shares. If quorum is not reached, meeting can be held at a second call. In this case, the meeting is duly constituted with any number of shareholders present. On the other hand, special meetings require the presence of members representing 60% of voting shares, unless articles provide for a higher quorum. If quorum is not reached, a meeting can be held at a second call. In this case, the meeting is duly constituted with the presence of members representing 30% of voting shares, unless the articles provide otherwise.

  • Must a bank account be opened prior to incorporation, and must the bank account be local?

    Not applicable for this jurisdiction.

  • Auditing of local financials. If so, must the auditor be located in local jurisdiction, and must the company's books be kept locally?

    All companies need to have at least annual financial statements audited. The auditor must be located in Argentina and the company's corporate and accounting books must be kept locally.

  • Requirement regarding par value of stock

    Not applicable for this jurisdiction.

  • Increasing of capitalization if needed

    Not applicable for this jurisdiction.

  • Summary of how funds can be repatriated from your jurisdiction (ie dividends or redemption)

    When approving annual financial statements, shareholders' meeting can resolve to distribute dividends, which will be transferred to respective shareholders.

  • Restrictions on transferability of shares

    Corporation (Sociedad Anónima or SA)

    No restrictions, unless otherwise provided in bylaws. Transfers are reported to the company and recorded in Stock Ledger Book.

    Single-Shareholder Corporation (Sociedad por Acciones Unipersonal or SAU)

    No restrictions, unless otherwise provided in bylaws. Transfers are reported to the company and recorded in  Stock Ledger Book.

    Simplified Corporation (Sociedad por Acciones Simplificada or SAS)

    No restrictions, unless otherwise provided in bylaws. Transfers are reported to the company and recorded in Stock Ledger Book.

    Limited Liability Company (Sociedad de Responsabilidad Limitada or SRL)

    No restrictions, unless otherwise provided in bylaws. Transfers shall be reported and registered with the Public Registry of Commerce.

  • Obtaining a name and naming requirements

    Corporate name must contain the type of company it adopted. Name may be reserved before registering the company by paying and filing a form with the Public Registry, in case chosen name is available.

  • Summary of "know your client" requirements

    Not applicable for this jurisdiction.

  • Approval requirements for amending charter document

    Amendments to bylaws in all companies must be approved by shareholders or members' meeting and then filed for registration by the Public Registry.

  • Licenses required to conduct business in jurisdiction

    Not applicable for this jurisdiction.

  • Process of purchasing and utilizing a shelf company

    Not applicable for this jurisdiction.

  • Key contacts
    Martin Mittelman
    Martin Mittelman
    Partner DLA Piper (Argentina) [email protected] T +5411 41145500 View bio
    Antonio Arias
    Antonio Arias
    Partner DLA Piper (Argentina) [email protected] T +5411 4114 5500 View bio

Tax presence

Argentina

Sociedad Anónima (Corporation) and SRL (LLC)

An S.A., same as an SRL (LLC), is considered an Argentine resident for tax purposes and is obligated to pay taxes on income obtained worldwide, whether earned within Argentina or abroad. An S.A. may take the sums effectively paid abroad for analogous taxes, for activities carried out abroad as a payment for taxes (within certain limits).

Australia

Branch

A foreign company is taxed as a separate entity in Australia and taxed on all income sourced from Australia. As the foreign company is carrying on an enterprise in Australia, it will also be required to register for Goods and Services Tax (GST).

Proprietary company

The company is taxed at a fixed rate on its income (and capital gains). Profits are usually distributed by way of dividend. Dividends may be "franked" in effect to give Australian tax resident recipient shareholders a credit for the tax paid by the company.

Public company

The company is taxed at a fixed rate on its income (and capital gains). Profits are usually distributed by way of dividend. Dividends may be "franked" in effect to give Australian tax resident recipient shareholders a credit for the tax paid by the company.

Austria

Limited Liability Company and Stock Corporation

AG and GmbH are taxed at two levels. First, the company/corporation pays a corporate income tax on its corporate income; then the company/corporation distributes profits to stockholders who are then taxed with income tax (withholding tax).

General Partnership and Limited Partnership

OG and KG are treated as being transparent for income tax purposes, as there is only one level of taxation. The corporate profits "pass through" to the owners, who pay taxes on the profits at their individual tax rates.

Bahrain

  • No personal income tax or corporate taxes payable
  • A corporate tax of 46% is imposed on oil, gas and related companies
  • As of January 1, 2019, Bahrain has introduced value added tax (VAT) at a standard rate of 5%. Some suppliers, however, are exempt or zero-rated. VAT generally applies on the supply of goods and services by domestic taxpayers as well as on the import of such goods and services. Under certain circumstances, foreign businesses with supplies in Bahrain may also fall within the scope of VAT

Belgium

Public limited company (société anonyme/naamloze vennootschap)

Subject to corporate income tax:

  • Belgian public limited companies are in principle taxable on their worldwide income, less allowable deductions. The taxable income is determined on the basis of the approved Belgian GAAP annual accounts, subject to certain adjustments in accordance with the Belgian Income Tax Code
  • Resident public limited companies are subject to a standard corporate income tax rate of 29.58%. This rate will be reduced to 25% as from 2020. The first income band of €100,000 of small public limited companies is subject to a lower rate of 20.40% (20% as from 2020) provided that certain conditions are met
  • A participation exemption regime exists for received dividends under which, subject to certain conditions, 100% of the received dividends are deductible. Capital gains realized on shares can be exempt provided that certain conditions are met
  • The payment of dividends, royalties and interest is in principle subject to a 30% withholding tax. Domestic law provides for reduced rates and exemptions in certain circumstances. The applicable rate may further also be reduced under an applicable double taxation treaty
  • Losses may in principle be carried forward indefinitely, but their use in a given tax year is limited to €1,000,000 plus 70% of the taxable basis in excess of €1,000,000
  • A CFC regime and a group consolidation regime will enter into force as from 2019

Limited company (société à responsabilité limitée/besloten vennootschap)

Subject to corporate income tax:

  • Belgian limited companies are in principle taxable on their worldwide income, less allowable deductions. The taxable income is determined on the basis of the approved Belgian GAAP annual accounts, subject to certain adjustments in accordance with the Belgian Income Tax Code
  • Resident limited companies are subject to a standard corporate income tax rate of 29.58%. This rate will be reduced to 25% as from 2020. The first income band of €100,000 of small limited companies is subject to a lower rate of 20.40% (20% as from 2020) provided that certain conditions are met
  • A participation exemption regime exists for received dividends under which, subject to certain conditions, 100% of the received dividends are deductible. Capital gains realized on shares can be exempt provided that certain conditions are met
  • The payment of dividends, royalties and interest is in principle subject to a 30% withholding tax. Domestic law provides for reduced rates and exemptions in certain circumstances. The applicable rate may further also be reduced under an applicable double taxation treaty
  • Losses may in principle be carried forward indefinitely, but their use in a given tax year is limited to €1,000,000 plus 70% of the taxable basis in excess of €1,000,000
  • A CFC regime and a group consolidation regime will enter into force as from 2019

Belgian branch office of a foreign company

A Belgian branch office of a foreign company will in principle be subject to tax on income generated by the Belgian branch office and will thus be subject to the so-called corporate non-resident income tax. The applicable tax rates are identical to the tax rates for resident companies. If a double taxation treaty is in place between Belgium and the state of tax residence of the foreign company, such treaty should be consulted in order to verify whether Belgium has the authority to tax the income that is attributable to the branch.

The foreign company (via its branch office) may also be subject to certain other possible taxes (such as registration taxes on the purchase of real estate or communal taxes).

Depending on its activities, the Belgian branch office may also qualify as VAT taxpayer.

Brazil

Limited liability company (Sociedade Limitada)

A legal entity incorporated in Brazil will be treated as a domestic legal entity for tax purposes, and subject to Brazilian income tax on its worldwide income.

Corporation (Sociedade Anônima)

A legal entity incorporated in Brazil will be treated as a domestic legal entity for tax purposes, and subject to Brazilian income tax on its worldwide income.

Canada

Corporate subsidiary (Corporation form rather than flow-through form) 

Canadian resident corporations are subject to federal and provincial/territorial corporate tax on worldwide income. Corporations are not subject to "branch profits tax" but are required to pay withholding tax on dividends and certain other amounts paid or distributed to non-Canadian resident shareholders, the rate of which varies depending upon the existence of a tax treaty between Canada and the shareholder's country of residence. This "dual layer of tax," ie first at the corporate level and then again upon distribution at the shareholder level, is sometimes referred to as double taxation. Share capital, however, can generally be repatriated free of any Canadian withholding tax (without first distributing E&P).

Chile

Chilean companies are taxed at two levels. First the company pays a "corporate tax" on its income and the stockholders pay a "personal tax" on dividends. Currently there are two tax regimes in force:

  • Attributed tax regime. Corporate tax is paid by the company and profits are deemed distributed to the stockholder, subject to the personal tax regardless of the effective distribution. Corporate tax is fully creditable against personal tax
  • Distributed or partially integrated tax regime. Corporate tax is paid by the company. The stockholder pays personal tax only on effective distribution by the company. Only 65% of the corporate tax is creditable against personal tax. If a DTT with Chile is applicable, stockholder is entitled to a full credit  

Branch of a foreign corporation (Agencia de Sociedad Anónima Extranjera)

Can freely opt between both regimes, however its default regime is partially integrated.

Corporation (Sociedad Anónima)

Mandatory partially integrated regime.

Limited liability company (Sociedad de Responsabilidad Limitada)

Can freely opt between both regimes, unless it has a Chilean entity as partner having mandatory partially integrated regime.

Limited liability partnership (Sociedad en Comandita)

Can freely opt between both regimes, unless it has a Chilean entity as stockholder having mandatory partially integrated regime.

Partnership limited by shares (Sociedad por acciones)

Can freely opt between both regimes, however its default regime is partially integrated.

China

An LLC is taxed at two levels (commonly referred to as double taxation). First the LLC pays an enterprise income tax on its corporate income; then the LLC distributes its after-tax profits as dividends to shareholders who then pay individual/enterprise income tax on those dividends.

Colombia

At a corporate level, all entities are taxed based on their earnings. At a personal level, partners and shareholders are taxed based on distributed dividends.

Czech Republic

A stock corporation or limited liability company is taxed at two levels: First the company pays a corporate income tax on its corporate income; then a company distributes profits to shareholders who then pay income tax on those dividends (to be withheld by the company upon payment).

Companies are obliged to add value-added tax (VAT) to the prices of their goods or services and to invoice their customers accordingly.

Denmark

Limited liability company (Kapitalselskab)

The profits of a limited company are taxed at two levels (commonly referred to as double taxation). Firstly, the limited company pays a corporate tax on its corporate income. Limited companies are subject to a Danish corporate income tax rate, which currently amounts to 22%.

Secondly, the shareholders pay tax on the distributed profits from the limited company.

Egypt

Corporations

  • Corporate entity is subject to income tax at the rate of 22.5% of its annual net profits

  • Employees' salaries are subject to income tax

  • The company makes a withholding tax at the rate of 10% upon distribution of dividends. As an exception, shareholders/quota-holders who own 25% of the company's shares/quotas for at least 2 years are subject to a withholding tax at a rate of 5%

  • Corporate entities must make social insurance contributions from both the employers and employees

  • Corporate entities, which sell goods or provide services which are subject to Value Added Tax (VAT) according to the VAT Law no. 67 of 2016, and whose annual turnover exceeds the amount of EGP 500,000, must be registered with the Egyptian Tax Authorities (ETA) for VAT purposes. By way of exception to the abovementioned threshold, Corporate Entities may apply to be registered for VAT purposes even if their turnover does not exceed said threshold provided that:

    • Their annual turnover during the twelve months prior to filing the registration application must not be less than EGP 150,000 or its paid up capital must not be less than EGP 50,000
    • They have registered physical office space through which they perform their registered activity and
    • They have a valid tax card
  • VAT at the rate of 14%, generally, is applied to all taxable local and imported goods and services, except:
    • Those specifically exempted by the VAT Law
    • Machinery and equipment used in the production of such goods and services which shall be levied at 5% and
    • All other products listed in the annex to the VAT Law which specifies the percentage of tax levied on them

Branch

  • A branch is subject to income tax at the rate of 22.5% of its annual net profits

  • Branch employees' salaries are subject to an income tax

  • The branch makes a withholding tax at the rate of 10% upon distribution of dividends and social insurance contributions from both the employers and employees

  • Branches, which sell goods or provide services subject to VAT and whose annual turnover exceeds the amount of EGP 500,000 must be registered with the ETA for VAT purposes

  • VAT at the rate of 14%, generally, is applied to all taxable local and imported goods and services, except:

    • Those specifically exempted by the VAT Law
    • Machinery and equipment used in the production of such goods and services which shall be levied at 5% and

    • All other products listed in the annex to the VAT Law which specifies the percentage of tax levied on them

RO

An RO's employees are subject to income tax and social insurance contributions from both employers and employees.

Finland

Osakeyhtiö (Oy)

The profits of an Oy are taxed at two levels (commonly referred to as double taxation). First, the Oy pays a corporate tax on its corporate income; then shareholders pay tax on the distributed profits from the Oy. Oy is subject to a Finnish corporate income tax rate, which currently amounts to 20%.

France

Société par actions simplifiée (SAS)

Are subject to French taxes, including corporate income tax (33 1/3%), withholding tax on profits and business tax as well as VAT.

Société à responsabilité limitée (SARL)

Are subject to French taxes, including corporate income tax (33 1/3%), withholding tax on profits and business tax as well as VAT.

Société anonyme (SA)

Are subject to French taxes, including corporate income tax (33 1/3%), withholding tax on profits and business tax as well as VAT.

Germany

GmbH – limited liability company

A GmbH is usually taxed on two levels:

  • Firstly, it is subject to corporate income tax (Körperschaftsteuer)
  • On the second level, a GmbH is subject to trade tax (Gewerbesteuer), which is imposed by local municipalities (ie, the town or city where the company is based)

Companies are obliged to add value-added tax (VAT – Mehrwertsteuer) to the prices of their goods or services and to invoice their customers accordingly.

Greece

Societe anonyme (S.A.)

The S.A. pays a corporate tax on its corporate income and then distributes dividends to shareholders who are taxed as well.

Limited liability company (L.T.D.)

Company pays a corporate tax on its corporate income and then distributes profits to partners. A tax of a specific rate is withheld for profits that are distributed by the company.

Private company (P.C.)

Company pays a corporate tax on its corporate income and then distributes profits to partners. A tax of a specific rate is withheld for profits that are distributed by the company.

Hong Kong

Limited private companies

A limited private company is taxed on its business profits at a corporate level. There are no tax on capital gains or dividends.

Hungary

Private company limited by shares (Zrt.)

A Zrt., as a Hungarian resident company, is taxed on its worldwide income subject to conditions of double tax treaty provisions. A company is resident if it has been incorporated in Hungary or has its place of effective management in Hungary.

Limited liability company (Kft.)

A Kft., as a Hungarian resident company, is taxed on its worldwide income subject to conditions of double tax treaty provisions. A company is a resident if it was incorporated in Hungary or has its place of effective management in Hungary.

India

Private limited company

A private limited company is taxed at two levels. First the company pays a corporate tax on its corporate income; then the company pays dividend distribution tax on profits distributed to shareholders. Further the shareholders pay an additional tax on dividend received in excess of INR1 million.

Sale or redemption of shares in the company is taxed as capital gains. Any indirect transfer of India shares can trigger indirect tax provisions.

Indonesia

Limited liability company

Corporate income tax is payable at a rate of 25%. 10% VAT is imposed on the delivery of goods and services.

Ireland

Private company limited by shares (LTD)

If Irish tax resident, a LTD is subject to Irish corporation tax on its worldwide income at 12.5% on its trading income and 25% for non-trading (passive) income.

If non-resident for Irish tax purposes, a LTD is not subject to Irish corporation tax unless it carries on a trade in Ireland through a branch or agency or if it receives income from Irish sources (for example, income from the rental of Irish properties).

 

External company

An Irish branch is subject to Irish corporation tax on:

  • Trading income arising directly or indirectly through or from the branch
  • Any income from property or rights used by, or held by or for, the branch and
  • Chargeable gains accruing on the disposal of Irish land and any assets situated in Ireland which are used for the purposes of a trade carried on by the Irish branch or are held for the purposes of the branch

Israel

Company

A company is taxed at two levels. First, the company pays a corporate tax on its corporate income; shareholders are then taxed on dividends distributed by the company (if distributed).

Branch / representative office

Only taxed at the corporate entity level on income.

Italy

Società a responsabilità limitata (S.r.l.)

Its earnings are taxed at a corporate level and quotaholders are taxed on any distributed dividends.

Japan

Registered branch

Income arising within Japan is in principle taxed, and income attributable to a branch arising in the countries other than Japan (if any) would be subject to income tax in Japan.

Kabushiki-Kaisha (KK)

A KK is taxed at two levels. First the KK is subject to corporate tax; then shareholders are taxed on any dividends distributed by the KK.

Godo-Kaisha (GK)

A GK is taxed at two levels. First the GK is subject to corporate tax; then members are taxed on any dividends distributed by the GK.

Luxembourg

Private limited liability company (Société à responsabilité limitée or S.à r.l.)

The company pays a corporate tax on its corporate income (currently at the rate of 27.08%) and a withholding tax may apply when dividends are paid to its shareholders (at the rate of 15%, subject to reduction under applicable tax treaties). Exemptions are available under certain conditions.

Public limited liability company (Société anonyme or S.A.)

The company pays a corporate tax on its corporate income (currently at the rate of 27.08%) and a withholding tax may apply when dividends are paid to its shareholders (at the rate of 15%, subject to reduction under applicable tax treaties). Exemptions are available under certain conditions.

Special limited partnership (Société en commandite spéciale or SCSp)

The SCSp is in principle tax transparent.

Malaysia

A private limited company pays a corporate tax on its profits. These profits may then be distributed to their shareholders as dividends.

Mexico

S.A. de C.V.

A S.A. de C.V. is taxed at two levels (commonly referred to as double taxation). First the S.A. de C.V. pays a corporate tax on its corporate income; then the S.A. de C.V. distributes profits to shareholders who then pay income tax on those dividends.

S. de R.L. de C.V.

A S. de R.L. de C.V. is taxed at two levels (commonly referred to as double taxation). First the S. de R.L. de C.V. pays a corporate tax on its corporate income; then the S. de R.L. de C.V. distributes profits to partners who then pay income tax on those dividends.

S.A.P.I. de C.V.

A S.A.P.I. de C.V. is taxed at two levels (commonly referred to as double taxation). First the S.A.P.I. de C.V. pays a corporate tax on its corporate income; then the S.A.P.I. de C.V. distributes profits to shareholders who then pay income tax on those dividends.

Netherlands

Branch office

Entities that are not a resident of the Netherlands for tax purposes are subject to Dutch corporate income tax, only if and to the extent income is derived and gains are realized from specific Dutch sources. An important category of income that is subject to Dutch corporate income tax is tax profit derived from a business carried on in the Netherlands by a non-tax resident entity via a Dutch permanent establishment or a Dutch permanent representative.

B.V. (private company with limited liability)

Dutch corporate income tax is imposed on the worldwide profits of the BV. The tax rate on the first €200,000 of taxable profit is 19%. The rate on taxable profit in excess of €200,000 is 25%. Benefits derived by the BV from a so-called “participation” (deelneming) in an entity are exempt from Dutch corporate income tax (participation exemption) (deelnemingsvrijstelling). The participation exemption seeks to prevent double taxation of business profits at different corporate levels.

Co-operative U.A.

Dutch corporate income tax is imposed on the worldwide profits of the Co-operative. The tax rate on the first €200,000 of taxable profit is 19%. The rate on taxable profit in excess of €200,000 is 25%. Benefits derived by the Co-operative from a so-called “participation” (deelneming) in an entity are exempt from Dutch corporate income tax (participation exemption) (deelnemingsvrijstelling). The participation exemption seeks to prevent double taxation of business profits at different corporate levels.

C.V. (a limited partnership)

A CV can either be considered tax transparent or opaque from a Dutch tax perspective. Depending on the partnership agreement, the tax status of the CV is determined.

New Zealand

Limited liability company

A company is subject to tax on its taxable profits. Profits are usually distributed by way of dividend. A company can attach imputation credits to a dividend that allows New Zealand tax resident shareholders to benefit from the tax paid by the company. In some circumstances, if imputation credits are attached then it is not necessary to withhold tax from dividends.

Goods and Services Tax (GST).

A limited liability company will generally be required to register for GST.

Branch

A foreign company is taxed as a separate entity in New Zealand and taxed on its taxable profits, which will include all income sourced from New Zealand less attributable expenses.

Goods and Services Tax (GST).

A foreign company is carrying on business in New Zealand through a branch may also be required to register for GST.

Norway

Private LLCs

Private LLCs are taxed at two levels. At first a private LLC pays a corporate tax on its corporate income; next a private LLC distributes profits to shareholders who then pay income tax on those dividends. Dividend received by legal entities being shareholders may be taxed at a lower level.

Public LLCs

Public LLCs are taxed at two levels. First, a public LLC pays a corporate tax on its corporate income; next a public LLC distributes profits to shareholders who then pay income tax on those dividends. Dividend received by legal entities being shareholders may be taxed at a lower level.

Partnerships with liability

Pass-through entity with only one level of taxation. The corporate profits "pass through" to the partners, who then pay taxes on the profits at their individual tax rates.

Philippines

Subsidiary

  • Subject to corporate income tax for income from sources within and out of the Philippines
  • Also subject to value-added tax (VAT) for gross receipts derived from sale, barter or exchange of goods or properties/services rendered in the Philippines
  • Also subject to local business taxes
  • Dividends received by the foreign entity/head office from its subsidiary are subject to withholding tax

Branch office

  • Subject to income tax from sources within the Philippines
  • Subject to VAT and local business taxes
  • Subject to branch profit remittance tax

Representative office

  • Not subject to income tax, VA or local business taxes

Regional or area headquarters

  • Not subject to corporate income tax, VAT or local business taxes

Regional operating headquarters

  • Subject to income tax and VAT

Partnership

  • Subject to regular corporate income tax, VAT and local business taxes

Poland

Corporations are subject to Polish taxes, including corporate income tax (19%), VAT on goods and services provided (different rates up to 23%) and personal income tax on dividends paid out (19%). Special conditions apply to branches and representative offices because they do not constitute separate legal entities under Polish law. Partnerships (except limited joint-stock partnerships) are exempt from corporate income tax – income tax is only paid by the partners.

Portugal

All companies are taxed at 2 levels: first, the corporation is taxed corporate tax on its income. Then, shareholders are taxed upon distribution of profits.

Puerto Rico

Corporations

A corporation is taxed at two levels (commonly referred to as double taxation). First, the corporation pays a corporate tax on its corporate income; then, when the corporation distributes profits to its shareholders, they pay income tax on those dividends.

Limited Liability Companies

LLCs are taxed by default as corporations and are subject to tax at both the business entity and member levels. However, LLCs may elect to be treated as partnerships for income tax purposes, receiving pass-through treatment by filing a Form SC 6045 Partnership or LLC Classification Notification no later than the last day of the third month following the LLC's date of organization or commencement of operations. Although a Puerto Rico LLC is automatically treated as a corporation for US federal income tax purposes, it may elect to be treated as a partnership or disregarded entity, as applicable. This election is accomplished through the filing of Form 8832 with the IRS.

Romania

Similar tax and accounting reporting requirements are applicable for both JSCs and LLCs sestablished in Romania. Further to the incorporation, both JSCs and LLCs are in principle subject to the following taxes:

  • The micro-companies tax: JSCs and LLCs will be liable to pay a micro-companies tax of 1% (if the company has at least one employee) or 3% (if the company has no employees), applied to the revenues registered, provided that the turnover obtained is below €1 million
  • Profit tax: if the registered turnover is higher than €1 million, JSCs and LLCs are subject to 16% profit tax, applied on the accounting profits adjusted for tax purposes
  • Value added tax (VAT): the standard VAT rate in Romania is currently 19%. The reduced VAT rates are of 9% (eg, for medicines, food and beverages - except alcohol, etc) or 5% (eg, for school manuals, books, newspapers and magazines, hotel accommodation and similar accommodation, restaurant and catering services, supplies of social housing including related land, in certain conditions). Registration for VAT purposes is required if the turnover resulting from the operations to be performed exceed the threshold of €88,500 (ie, RON 300,000)
  • Local tax: due by companies for assets in their patrimony (ie, for buildings, land and vehicles owned) or taxes on publicity and advertising and outdoor advertising
  • Withholding tax (WHT): WHT is due on payment of dividends, interest, royalties, commissions and services. As per the domestic tax legislation, income derived by non-residents from Romania is, as a general rule, subject to 16% WHT in Romania. However, such rates can be reduced (even to nil) under the provisions of the EU Directives or double tax treaties entered into by Romania with different countries
  • Salary and mandatory social security charges: the existence of employees at the level of the JSC and LLC trigger salary tax and related social security contributions. A flat income tax rate of 10% applies to the income obtained. Moreover, both the employer and the employee are required to contribute to the social security system (ie, pension and health contribution for the employee and labor insurance contribution of 2.25% for the employer)
  • Customs duties: applicable if JSC or LLC performs imports of goods from outside the EU to Romania (certain exemptions may apply though)
  • Accounting requirements: both JSCs and LLCs are required to organize and manage its own accounts based on the Romanian accounting rules

Russia

Joint-stock company (public and non-public)

A company is taxed at two levels. First the company pays profits tax on its corporate income; then the company distributes dividends to shareholders and withholds the income tax on those dividends (where paid in cash) acting as a tax agent. Certain tax exemptions are available. 

Limited liability company

A company is taxed at two levels. First the company pays profits tax on its corporate income; then the company distributes profits to members and withholds the income tax on those profits (where paid in cash) acting as a tax agent. Certain tax exemptions are available.

Saudi Arabia

Limited liability company

As of January 1, 2018, 5% value-added tax (VAT) has been introduced on most goods and services.

Singapore

Limited liability company

A company is resident for Singapore tax purposes if it is managed and controlled in Singapore. In practice, the Inland Revenue Authority of Singapore (IRAS) considers a company is managed and controlled in Singapore if the Board of Directors meetings where strategic decisions are made are held in Singapore.

South Africa

Private companies and public companies

Private and public companies must register as taxpayers with the South African Revenue Service.

All South African resident companies are expected to pay Corporate Income Tax (CIT) on the income generated worldwide, while non-resident companies are taxed only on their income which is sourced in South Africa. Current CIT rate is 28%.

There is a tax on dividends. It is withheld by the South African resident companies when paying out dividends to shareholders. Current tax rate for dividends is 20% on the dividends declared and paid by companies, subject to treaty relief.

Companies are required to pay Capital Gains Tax on their net capital gains for the year at an effective rate of 22.4% and other exemptions.

It is mandatory for any business to register for Value-Added Tax (VAT) with the South African Revenue Service if its taxable supplies in any 12-month period exceeds R1 million or when it has a contractual obligation in writing to make supplies of R1 million in a 12-month period. A business may also choose to voluntarily register for VAT if the value of taxable supplies made or to be made is less than R1 million, but has exceeded R50 000 in the past 12 months. The VAT rate is currently 15%.

External companies

If an external company retains its effective management offshore, it will be considered a non-resident and therefore will only be charged CIT on South African sourced income.

Dividends' tax is not imposed on any profits remitted offshore. Same VAT requirements for private and public companies apply to an external company.

South Korea

Joint-stock company (Jusik Hoesa)

A joint-stock company pays corporate tax on its corporate income and distributes profits to shareholders who then pay income tax on those dividends.

Limited company (Yuhan Hoesa)

A limited company pays corporate tax on its corporate income and distributes profits to members who then pay income tax on those dividends.

Spain

Branch (Sucursal)

Branches are taxed on the profits allocated to the permanent establishment.

Limited liability company (Sociedad Limitada)

Taxed on its earnings at a corporate level and shareholders are taxed on any distributed dividends, although double taxation relief may apply.

Joint-stock company (Sociedad Anónima)

Taxed on its earnings at a corporate level and shareholders are taxed on any distributed dividends, although double taxation relief may apply.

Sweden

Limited company (Sw. aktiebolag, AB)

Profits of an AB are taxed at two levels (commonly referred to as double taxation). First an AB pays a corporate tax on its corporate income; then shareholder's pays tax on profits distributed from an AB. AB is ssubject to a Swedish corporate income tax rate which currently amounts to 21.4%.

Trading partnership (Sw. handelsbolag, HB)

Partners are taxed based on their part of HB's surplus and includes income tax and social security contribution.     

Limited partnership (Sw. kommanditbolag, KB)

Partners are taxed based on their part of KB's surplus and includes income tax and social security contribution.    

Branch office (Sw. filial, Branch)

A foreign company starting a branch in Sweden must pay income tax on its business operations. Branch accounts must be kept separate from those of a foreign company in order to calculate the accrued profit. Profit of a branch is then subject to Swedish corporate income tax rate which currently amounts to 21.4%.

Switzerland

Stock corporation

A stock corporation is taxed at two levels (so-called economic double taxation). First the stock corporation pays a corporate tax on its corporate income; when the stock corporation distributes profits to shareholders, they pay income tax on those dividends. Capital tax is only levied on a cantonal and communal level.

Taiwan

Company limited by shares

A company (including an FIA company) is taxed on its worldwide net income.

Closely-held company limited by shares

A CHC (including an FIA company) is taxed on its worldwide net income.

Limited company

A company (including an FIA company) is taxed on its worldwide net income.

Branch office of a foreign company

The net profit of a branch office is subject to corporate income tax, but after-tax profits can be repatriated to its foreign company free from additional tax.

Thailand

Private limited company

A private limited company is subject to corporate income tax. The shareholders are subject to income tax on the dividends paid to them.

Public limited company

A public limited company is subject to corporate income tax. The shareholders are subject to income tax on the dividends paid to them.

Partnerships

Unregistered ordinary partnership

Partners of an unregistered ordinary partnership must pay personal income tax at a progressive rate.

Registered ordinary partnership

A registered ordinary partnership is subject to corporate income tax. The partners are subject to income tax on the profit distributions from the registered ordinary partnership.

Limited partnership

A limited partnership is subject to corporate income tax. The partners are subject to income tax on the profit distributions from the registered limited partnership.

Turkey

Joint-stock company (JSC)

A JSC's profit is subject to 22% corporation income tax.

Limited liability company (LLC)

An LLC's profit is subject to 22% corporation income tax.

United Arab Emirates

LLC

No personal income tax or corporate taxes payable, save for companies engaged in oil, gas, hospitality and petrochemical activities, etc. There are some municipality taxes paid on rent and certain land transfer charges paid when transferring real estate. Effective January 1, 2018, the UAE has implemented a value added tax (VAT) at a rate of 5%, as recommended by the World Bank and the International Monetary Fund.

Branch

Same as LLC.

FZ-LLC

No personal income tax or corporate taxes payable. Certain designated free zones in the UAE have been exempt from payment of VAT but in all other non-designated free zones, VAT is applicable. The designated free zones which are exempt from VAT are set out below:

Abu Dhabi

  1. Free Trade Zone of Khalifa Port
  2. Abu Dhabi Airport Free Zone
  3. Khalifa Industrial Zone

Dubai

  1. Jebel Ali Free Zone (North-South)
  2. Dubai Cars and Automotive Zone (DUCAMZ)
  3. Dubai Textile City
  4. Free Zone Area in Al Quoz
  5. Free Zone Area in Al Qusais
  6. Dubai Aviation City
  7. Dubai Airport Free Zone

Sharjah

  1. Hamriyah Free Zone
  2. Sharjah Airport International Free Zone

Ajman

  1. Ajman Free Zone

Umm Al Quwain

  1. Umm Al Quwain Free Trade Zone in Ahmed Bin Rashid Port
  2. Umm Al Quwain Free Trade Zone on Sheikh Monhammed Bin Zayed Road

Ras Al Khaimah

  1. RAK Economic Zone (RAKEZ)
  2. RAK Maritime City Free Zone
  3. RAK Airport Free Zone

Fujairah

  1. Fujairah Free Zone
  2. Fujairah Oil Industry Zone (FOIZ)

FZ-Branch

Same as FZ-LLC.

Dual Licence Branch

Same as Branch.

United Kingdom

Private limited company

Company's profits taxed at 2 levels: Corporation tax is applied directly on the company's profits. In addition, income tax is imposed on any dividends distributed to shareholders. Company may be under a duty to withhold tax (eg, when paying interest).

Limited liability partnership (LLP)

Generally taxed as a partnership. Individual members liable for income and capital gains tax on their share of LLP's profits/gains.

Registered UK establishment

An overseas company is subject to corporation tax on its profits only to the extent that those profits are attributable to the UK establishment.

United States

C corporation

A C corporation is taxed at two levels (commonly referred to as double taxation). First the C corporation pays a corporate tax on its corporate income; then the C corporation distributes profits to stockholders who then pay income tax on those dividends.

S corporation

Pass-through entity taxed like a partnership, as there is only one level of taxation. The corporate profits “pass through” to the owners, who pay taxes on the profits at their individual tax rates.

Limited liability company (LLC)

Unless the LLC elects to be treated as a corporation, it is a pass-through entity taxed like a partnership, as there is only one level of taxation. The corporate profits “pass through” to the owners, who pay taxes on the profits at their individual tax rates.

Vietnam

Joint stock company (JSC)

An entity is liable to pay corporate income tax levied on its earnings, and shareholders/members (only individuals) are taxed on any distributed dividends.

Multi-member limited liability company (2M-LLC)

An entity is liable to pay corporate income tax levied on its earnings, and shareholders/members (only individuals) are taxed on any distributed dividends.

Single-limited liability company (IM-LLC)

A 1M-LLC is liable to pay corporate income tax imposed on its earnings. However, the sole member (either a legal entity or an individual) is not taxed on its distributed profits.