US Company Formation from Austria, Luxembourg, Czechia, Slovakia, Slovenia, Hungary, Romania, Bulgaria and Croatia (2026): Treaties, Inc or LLC, Costs and Banking
Forming a US company from Austria, Luxembourg, Czechia, Slovakia, Slovenia, Hungary, Romania, Bulgaria or Croatia: treaty status, Inc or LLC, costs, banking.
Founders across Central and Eastern Europe build software, games, outsourcing businesses and e-commerce brands for customers worldwide, and the USA is usually their largest market. Companies in Vienna and Luxembourg expand there, development studios in Prague, Bratislava, Ljubljana, Bucharest, Sofia and Zagreb serve US clients, and startups across the region raise from US investors.
The US side of forming a company is the same everywhere and fully remote. What differs most across this region is the tax treaty position with the USA: most of these countries have a treaty, but Hungary's treaty was terminated from 2024, and Croatia's treaty has been signed but is not yet in force. This guide covers Austria, Luxembourg, Czechia, Slovakia, Slovenia, Hungary, Romania, Bulgaria and Croatia together, with the points that matter for each. For Poland, see our Poland guide.
Short answer: residents of these countries can own 100% of a US corporation or LLC, formed remotely, and a local company can own a US subsidiary. With UCB, a Delaware corporation with EIN is $308 all-in, and a Wyoming LLC with EIN is $249. Austria, Luxembourg, Czechia, Slovakia, Slovenia, Romania and Bulgaria have income tax treaties with the USA that reduce US withholding on dividends and limit US tax on business profits to a US permanent establishment. Hungary has had no treaty since 1 January 2024, so dividends from a US corporation to a Hungarian resident face 30%. Croatia's first treaty with the USA was signed in 2022 and amended in 2026 but is not yet in force. At home, all are EU countries with CFC rules, their own classification of a US LLC, and tax residence for companies managed locally. Agree the structure with a local adviser first.
Can residents of these countries own a US company?
Yes. US states place no restriction on nationality or residence. You can own 100% of a US LLC or corporation, be its only director or manager, and form it remotely with no US visa, SSN or US address. A registered agent in the US state is included for the first year in every UCB formation. See open a US company without visiting.
Treaty position by country
| Country | Income tax treaty with the USA | What it means for a US corporation's dividends to an individual |
|---|---|---|
| Austria | Yes | Reduced treaty rate (generally 15%) with a valid W-8BEN |
| Luxembourg | Yes | Reduced treaty rate (generally 15%) with a valid W-8BEN |
| Czechia | Yes | Reduced treaty rate (generally 15%) with a valid W-8BEN |
| Slovakia | Yes | Reduced treaty rate (generally 15%) with a valid W-8BEN |
| Slovenia | Yes | Reduced treaty rate (generally 15%) with a valid W-8BEN |
| Romania | Yes | Reduced treaty rate with a valid W-8BEN |
| Bulgaria | Yes | Reduced treaty rate with a valid W-8BEN |
| Hungary | No: terminated from 1 January 2024 | 30% US withholding; no treaty protection for business profits |
| Croatia | Signed (2022, amended 2026), not yet in force | 30% until the treaty enters into force |
Treaty rates also depend on the treaty's limitation-on-benefits rules, so we confirm the position for each owner. See W-8BEN-E vs W-8BEN explained.
LLC or corporation on the US side
| US LLC (single-member) | US C-Corporation | |
|---|---|---|
| US federal tax if all work is done from home | Usually none | 21% of profits |
| US tax on profits paid to the owner | None (not a dividend) | Treaty rate, or 30% for Hungary and Croatia |
| Yearly federal filing | Form 5472 + pro forma 1120 | Form 1120 + Form 5472 |
| Investors | Most will not invest | Standard (Delaware) |
A single-member LLC run entirely from abroad usually owes no US federal income tax, but files Form 5472 every year, with a $25,000 penalty if missed. For Hungarian and Croatian residents without treaty protection, the LLC's advantage on the US side is larger, because a corporation's dividends face 30%; but US tax on business profits then depends only on US domestic rules, with no permanent establishment test. See effectively connected income explained, Form 5472 explained and LLC vs Inc for non-residents.
The home side
All nine are EU member states (Luxembourg and Austria in Western Europe, the rest in Central and Eastern Europe), and EU law requires CFC rules for corporate taxpayers; several apply similar rules to individuals. Points to raise with your local adviser:
- Classification. Each country classifies a US LLC under its own rules, usually by comparison with local company and partnership forms. A single-member LLC that the IRS ignores is often treated as a company at home.
- Place of management. A US company effectively managed from your country can be taxed there as a resident company.
- Low-taxed foreign companies. A US LLC that pays no US tax can fall within CFC rules if a local company owns it, and sometimes if you do.
- Your local company owning or working for the US company needs transfer pricing documentation.
- Hungary and Croatia: without a treaty in force, double taxation relief depends on domestic rules only, so planning matters more.
- Luxembourg: often used for holding structures; a Luxembourg company owning a US company needs advice on both countries' anti-hybrid rules.
We handle the US side; your local adviser confirms the home side.
Which US state, and what it costs
Delaware for startups and subsidiaries; Wyoming or New Mexico for a simple company without investors. See Delaware, Wyoming, New Mexico and the state selector.
| With UCB | |
|---|---|
| Delaware corporation with EIN, all-in | $308 |
| Keeping a Delaware corporation active each year | $578 |
| Wyoming LLC with EIN, all-in | $249 |
| Wyoming LLC with EIN and US bank account application | $348 |
| Keeping a Wyoming LLC active plus the federal return | $421 |
State fees and the first-year registered agent are included. See the cost calculator.
Documents and banking
A passport or national ID card, proof of address, two or three company names, a business description and, for a corporation, the share structure; add your local company's register extract if it will own the US company. No SSN, ITIN or US address is needed. EU residents are generally well served by US fintech banks; consistent details and a US business address with your own suite number help. See US business bank accounts for non-residents and Stripe for non-residents.
Worked examples
These are illustrative examples, not client cases.
Example 1: the Prague development studio. A Czech s.r.o. building software for US clients forms a Delaware subsidiary to sign US contracts. The subsidiary pays US tax on its own margin; transfer pricing between the companies is documented.
Example 2: the Budapest freelancer. A Hungarian developer with US clients forms a Wyoming LLC. Without a US–Hungary treaty, an LLC avoids the 30% dividend withholding a corporation would face; their Hungarian adviser confirms how Hungary taxes the LLC's profits.
Example 3: the Bucharest startup. Romanian founders raising from US investors form a Delaware C-Corporation above their Romanian SRL, with lawyers handling the structure.
Example 4: the Vienna company's US sales office. An Austrian GmbH forms a Delaware subsidiary to employ US sales staff.
Common mistakes
- Assuming Hungary still has a US treaty, or that Croatia's signed treaty is already in force.
- Assuming a US LLC is transparent at home.
- Running a US company entirely from home without considering local tax residence.
- Ignoring CFC rules when a local company owns a low-taxed US LLC.
- Ignoring Form 5472.
How UCB helps founders in Central and Eastern Europe
We form US corporations and LLCs for residents of the region remotely, all-in, keep them active and file the federal return through our US tax filing service, working alongside your local adviser. See also the Germany, Poland and Baltic guides, and the country guide.
Expanding from Central or Eastern Europe to the USA? WhatsApp us at +91 8105 199 399 or email enquiries@ucbsolutions.com, and we will recommend the right structure and state for you.
Let our experts handle it for you
Every business is different. Message us with your country, business type and goals, and we will recommend the right structure, state and package. We do the work; you focus on your business.
This article is general information for non-resident business owners and is not legal or tax advice. Rules and fees change; contact us to confirm what applies to your situation.
