Navigate tax obligations, filing requirements, and compliance frameworks across jurisdictions. Understand your responsibilities before you start.
Tax compliance is where many global founders stumble. Unlike formation (one-time) or banking (straightforward), tax involves ongoing obligations across multiple jurisdictions, often with conflicting rules and reporting requirements.
This guide breaks down corporate tax obligations, personal tax considerations, and compliance calendars for the most common founder structures. We focus on practical clarity: what you must file, when, and what happens if you don't.
Important Disclaimer
This is educational content, not tax advice. Tax laws are complex and jurisdiction-specific. Always consult a qualified tax professional for your specific situation. See our full disclaimer.
| Entity Type | Corporate Tax Return | Annual Report/Filing | Audit Required | Typical CPA Cost | Complexity Level |
|---|---|---|---|---|---|
| Delaware C-Corp | Form 1120 by Apr 15 | March 1 (Franchise Tax) | No (unless required by investors) | $2,000-5,000/yr | High |
| Wyoming LLC | Form 1065 by Mar 15 | Anniversary month (Annual Report) | No | $500-2,000/yr | Low-Medium |
| UK Limited | CT600 within 12 months | Accounts within 9 months | No (for small companies) | $600-1,500/yr | Medium |
| Singapore Pte Ltd | Form C-S by Nov 30 | ACRA Annual Return | Yes (most companies) | $2,000-4,000/yr | High |
| Estonia OÜ | Annual tax declaration | Annual report (online) | No (for small companies) | $1,200-2,400/yr | Low |
| Hong Kong Limited | Profits Tax Return (18 months after) | Annual Return with Registry | Yes | $1,500-3,000/yr | Medium-High |
CPA costs reflect basic compliance for companies with straightforward operations. Complex situations (multi-jurisdictional, R&D credits, etc.) cost significantly more.
| Jurisdiction | Tax Type | Standard Rate | Registration Threshold | SaaS Taxable? | Filing Frequency |
|---|---|---|---|---|---|
| United States | Sales Tax | 0-10% (varies by state) | Economic nexus thresholds | Yes (most states) | Monthly/Quarterly |
| United Kingdom | VAT | 20% | £90,000 annual turnover | Yes | Quarterly |
| European Union | VAT | 17-27% (varies) | €10,000 (cross-border digital) | Yes | Quarterly (OSS) |
| Singapore | GST | 9% | $1M SGD annual revenue | Yes | Quarterly |
| Hong Kong | None | 0% | N/A | N/A | N/A |
| Estonia | VAT (KM) | 22% | €40,000 (EU digital services) | Yes | Monthly/Quarterly |
| Australia | GST | 10% | $75,000 AUD annual turnover | Yes | Quarterly/Monthly |
Rates and thresholds as of December 2025. SaaS taxation rules vary significantly—always consult a tax professional for your specific product and customer locations.
Double taxation structure
Corporate Level: 21% federal corporate tax on worldwide income (though many startups have no profit in early years). State corporate tax varies (Delaware: 8.7% on Delaware-source income).
Shareholder Level: Dividends taxed at personal rates (15-20% qualified dividend rate for US taxpayers). This is the "double taxation"—profits taxed at corporate level, then again when distributed.
Foreign Founder Considerations: If you're a non-US resident founder with no US physical presence, you generally don't owe US personal income tax on salary/distributions (though 30% withholding may apply to dividends unless tax treaty reduces it). Your home country may tax worldwide income.
Required Filings: Form 1120 (federal corporate return), state returns, Form 5472 if foreign-owned, quarterly estimated tax payments if profitable. CPA typically required ($2K-5K/year for startups).
Sales Tax: If you have US customers, you may owe sales tax in states where you have "nexus" (physical presence or economic threshold). Varies by state. SaaS generally subject to sales tax in many states now.
Pass-through taxation
Pass-Through Structure: LLC itself doesn't pay federal income tax. Profits and losses "pass through" to members' personal tax returns. Single-member LLC is disregarded entity (treated as sole proprietorship for tax).
Foreign Member Tax Treatment: Non-US members generally only owe US tax on US-source income. If all your customers/operations are outside the US, you likely owe zero US income tax (though you still must file). Consult tax advisor for "effectively connected income" rules.
Required Filings: Form 1065 (partnership return) if multi-member, Schedule C if single-member, Form 5472 if foreign-owned. Wyoming has no state income tax. Much simpler than C-Corp.
Self-Employment Tax: US-based members pay 15.3% self-employment tax on profits (Social Security + Medicare). Foreign members generally exempt if no US presence.
Home Country Tax: Most countries tax worldwide income for residents. If you're a tax resident of France/Germany/etc., you'll likely owe tax there on LLC profits (though US-paid tax may be creditable under tax treaty).
Corporation tax + dividend tax
Corporation Tax: 19% (profits up to £50K) or 25% (profits over £250K). Applied to company profits. Must file CT600 return within 12 months of accounting period end. Payment due 9 months + 1 day after period end.
Dividend Tax: Shareholders pay personal tax on dividends: 8.75% (basic rate), 33.75% (higher rate), 39.35% (additional rate). First £500 dividend allowance is tax-free (as of 2024/25).
Non-UK Resident Directors: If you're not a UK tax resident, you generally don't pay UK personal income tax on salary/dividends from UK company, but the company still owes corporation tax on UK-source profits. Check treaty.
Required Filings: Annual accounts (filed with Companies House), confirmation statement, CT600 (corporation tax return), Self Assessment if you're UK tax resident director.
VAT: Must register for VAT if turnover exceeds £90K (2024 threshold). 20% standard rate. Quarterly VAT returns via HMRC online. Complex if selling to EU/international customers.
Territorial tax with exemptions
Corporate Tax: 17% flat rate on Singapore-source income. New companies enjoy partial tax exemptions (first $100K often 75% exempt, next $100K often 50% exempt). Effective rate for first $200K can be ~4.25%.
Territorial System: Singapore doesn't tax foreign-source income (with conditions). If you're a SaaS serving global customers and operate remotely, careful structuring can minimize Singapore tax. Requires substance and proper documentation.
Dividend Tax: Singapore has zero capital gains tax and zero dividend tax. Dividends paid out of Singapore-taxed profits are tax-free to shareholders (one-tier system).
Required Filings: Form C-S or C (corporate tax return) by November 30 following fiscal year end. Annual returns with ACRA. Audited financials required for most companies (unless exempt small company).
GST: Must register if revenue exceeds $1M SGD. 9% GST (2024 rate). Can be complex for international SaaS—consult advisor.
Zero tax on retained earnings
Unique Tax System: 0% corporate tax on retained earnings. Tax only triggered when profits are distributed (20% on gross distribution, effective ~25.6% on net distribution). No tax if you reinvest profits in business.
Personal Tax for Directors: If you pay yourself a salary, normal payroll taxes apply (~33% social tax + 20% income tax in Estonia). Many e-residents pay minimal salary and take dividends from other jurisdictions.
Non-Resident Considerations: If you're not an Estonian tax resident, Estonia doesn't tax your personal income. OÜ only owes Estonian tax when distributing profits. Your home country may tax the distributions.
Required Filings: Annual report (very simple online), tax declaration. No audit required for small companies. Accounting can be done remotely (~€100-200/month via Estonian services).
VAT: Must register if EU sales exceed €40K. 22% rate. MOSS (Mini One-Stop Shop) for digital services to EU consumers simplifies compliance.
Territorial tax system
Territorial Tax: Only Hong Kong-source profits are taxed. Two-tier system: 8.25% on first HK$2M, 16.5% above. If your income is non-Hong Kong source (e.g., SaaS serving global customers with no HK operations), you may claim offshore exemption.
Offshore Claims: Requires careful documentation and advisor support. Inland Revenue Department scrutinizes these claims. Must prove activities generating income occurred outside HK.
Dividend Tax: No tax on dividends in Hong Kong. No capital gains tax.
Required Filings: Profits tax return (annually), annual return with Companies Registry, audited accounts (audit required for most companies). First return due ~18 months after incorporation.
Compliance Cost: Higher than most jurisdictions. Audit + tax filing typically $1.5K-3K/year. Dormant company filings cheaper (~$500).
| Entity Type | Filing Requirement | Deadline | Penalty for Late Filing |
|---|---|---|---|
| Delaware C-Corp | Form 1120 (Federal) | April 15 or Oct 15 (extension) | 5% per month, max 25% |
| Delaware C-Corp | Franchise Tax | March 1 | $200 + 1.5% interest/month |
| Wyoming LLC | Annual Report | First day of anniversary month | $50 + potential dissolution |
| UK Ltd | Corporation Tax (CT600) | 12 months after period end | £100-£1,000+ |
| UK Ltd | Annual Accounts | 9 months after year end | £150-£1,500 |
| Singapore Pte Ltd | Form C-S/C | Nov 30 (for Dec 31 YE) | $200+ late filing penalty |
| Estonia OÜ | Annual Report | 6 months after year end | €100-400 fine |
Deadlines vary based on fiscal year end. This table assumes standard calendar year (Dec 31 year end) where applicable.
You're a non-US citizen traveling constantly, running a SaaS via US LLC. Generally owe zero US income tax (no US-source income, no US presence). Must file Form 5472 + pro forma 1120. Your tax liability is in your country of tax residence (if any).
Company owes 21% federal tax on profits (often $0 in early years). You owe zero US personal income tax if no US presence. Must file 1120 + 5472. If taking salary, withholding may apply. Home country may tax dividends.
0% corporate tax in Estonia if you don't distribute profits. Must pay personal income tax in your EU country of residence. Estonia OÜ doesn't exempt you from home country tax—it's a deferral mechanism for corporate tax only.
If you live in Singapore, pay 17% corporate tax (with exemptions) + personal income tax on salary/dividends. If you live elsewhere, Singapore company owes 17% on SG-source income, you owe personal tax where you're tax resident.
1. Entity-Market Alignment: Match your entity jurisdiction to your primary market. US entity for US customers, UK/EU entity for European sales, Singapore for Asia. This minimizes cross-border complexity.
2. Substance Over Form: Tax authorities increasingly look for "substance"—real offices, employees, board meetings in your entity's jurisdiction. Mailbox companies with no operations face scrutiny and potential tax challenges.
3. Know Your Tax Residency: Your personal tax residency (usually based on where you spend most time) determines where you owe personal income tax. Entity location doesn't change this. Don't assume incorporating offshore = zero tax.
4. Document Everything: Keep records of where work was performed, where contracts were signed, where decisions were made. Critical for territorial tax claims and offshore exemptions.
5. Hire a Pro Early: Tax compliance mistakes are expensive. A qualified international tax CPA/advisor ($2K-5K/year) saves multiples of their fee in avoided penalties and optimizations.
Even if you owe $0 tax, most jurisdictions require filing. Not filing can lead to penalties, interest, bank account issues, and entity dissolution. File on time, even for zero-revenue years.
Incorporating offshore doesn't exempt you from tax where you live. Most countries tax worldwide income of residents. You may owe tax at home even if your company paid tax elsewhere.
Tax authorities challenge companies with no real presence in their incorporation jurisdiction. If all operations happen elsewhere, your entity may be deemed tax resident where you actually work.
Treating employees as contractors to avoid payroll taxes is a common mistake. Authorities audit this aggressively. Leads to back taxes, penalties, and legal liability.
Find the right structure and understand your compliance obligations before you start.