Dual Company: US LLC & UK Ltd for Course Creators in 2026

This dual structure addresses core needs for non-US course creators. The US LLC provides access to US-centric payment gateways like Stripe and PayPal, which are often stringent on non-US entities. It offers a level of credibility, especially when selling to US audiences.

The UK Ltd, on the other hand, provides a respected corporate structure within Europe. It simplifies VAT registration for EU sales and offers an established framework for managing international income. Combined, these entities allow global reach with localized compliance.

The US LLC serves as your primary sales and payment collection entity. Stripe, PayPal, and even many course platforms (Teachable, Thinkific, Kajabi) prefer or require a US entity for integration and payouts. This means your US LLC will sign agreements with these platforms.

Crucially, the US LLC funnels all global course sales revenue. This centralizes income, simplifying reporting for your primary operational entity (the UK Ltd). A Wyoming or New Mexico LLC offers privacy benefits, which can be valuable for sole founders.

Maintaining a US LLC costs around $50 to $500 annually in state fees, plus registered agent fees of $100 to $150. Formation costs range from $300 to $700, depending on the service provider.

The UK Ltd acts as the operational hub, employing you and receiving profits from the US LLC. As a non-resident of the UK, you can own and direct a UK Ltd entirely remotely. Its primary advantage is simplified accounting and potentially lower tax for un-retained profits if structured correctly.

The UK Ltd can issue invoices for services rendered (e.g., course content development, marketing) to the US LLC. This creates a legitimate expense for the US LLC, reducing its taxable income, and transferring the profit to the UK Ltd. The UK Ltd then pays you a salary or dividends.

First, form your US LLC. Choose a state like Wyoming or New Mexico for privacy. Obtain an Employer Identification Number (EIN) for your LLC. This can be done without an SSN or ITIN, even in 2026, by faxing Form SS-4 to the IRS. Bastion Formations can assist with this.

Next, form your UK Ltd. This typically takes 24-48 hours through a company formation agent. You will need a registered address in the UK, which is provided by the agent. You are appointed as the director and shareholder.

Ensure your US LLC is 100% owned by the same individual(s) who own the UK Ltd. This simplifies inter-company agreements and tax reporting.

For your US LLC, securing a business bank account remotely is essential. Fintech banks like Mercury, Relay Financial, or Wise (formerly TransferWise) offer accounts for non-resident-owned US LLCs. These support Stripe and PayPal payouts. Expect KYC (Know Your Customer) checks that require passport and proof of address.

For your UK Ltd, Wise Business offers multi-currency accounts that work well. Alternatively, some traditional UK banks like Revolut Business or Barclays (with stricter KYC) can open accounts for non-resident directors. This gives you easy access to GBP and EUR transactions.

Integrate your US LLC's bank account with Stripe, PayPal, and your chosen course platform. Set up an inter-company transfer mechanism (e.g., via Wise) for the US LLC to pay the UK Ltd for services or as profit distribution.

The US LLC, if it's a single-member LLC, is a disregarded entity for US tax purposes. It does not pay US federal income tax as long as it has no US physical presence and its income is not 'effectively connected income.' However, it must file Form 5472 and Form 1120 proforma annually, reporting its income and ownership. Failure to file incurs a $25,000 penalty.

For the UK Ltd, if it has no UK employees, no UK substance, and its 'central management and control' is outside the UK, its profits might not be subject to UK Corporation Tax, under 'Double Taxation Agreements.' However, this is a complex area requiring professional tax advice in both jurisdictions. Even with zero taxable profit, you must file annual accounts (Companies House) and a Corporation Tax return (CT600) with HMRC.

You will pay personal income tax in your country of residence on the salary or dividends you take from the UK Ltd. The UK Ltd will also need to register for VAT if its annual sales to UK customers exceed £90,000 (2026 threshold). Sales to EU customers require separate MOSS or OSS registration for VAT.

Both entities require annual compliance. The US LLC needs its annual reports filed with the state (e.g., Wyoming is $60 yearly) and the federal tax filings (Form 5472, 1120 proforma). Ensure you maintain a registered agent and a virtual office address for your US LLC.

The UK Ltd requires annual confirmation statements, statutory accounts, and a CT600 Corporation Tax return. These filings are critical. Consider professional accounting services for both entities to ensure full compliance and optimize tax efficiency. This service might cost $1,500 to $3,000 annually for both entities combined.