🇬🇧 United Kingdom vs 🇺🇸 United States (Delaware)
A side-by-side look at setting up a company in United Kingdom (Private Limited Company) and United States (Delaware) (Delaware C-Corp / LLC), plus 3 regulatory differences to plan for if you operate in both.
| Criterion | United Kingdom | United States (Delaware) |
|---|---|---|
| Typical vehicle | Private Limited Company | Delaware C-Corp / LLC |
| Foreign ownership | 100% | 100% |
| Minimum capital | GBP 1 | None |
| Time to incorporate | 1–3 days | 1–5 days |
| Corporate tax | 25% (19% small profits) | 21% federal + state |
| VAT / GST | 20% | State sales tax |
| Dividend withholding | 0% | 30% (treaty relief) |
| Resident director | Not required | Not required |
| Physical office | Virtual accepted | Virtual accepted |
| Annual running cost | USD 1,500–5,000 | USD 2,000–7,000 |
| Audit | Threshold-based | Not mandatory |
| Legal system | Common law | Common law |
| Currency controls | None | None |
Operating in both: key conflicts
Employment: Termination regimes conflict
A single global employment template cannot be used: at-will clauses are unenforceable in the protective jurisdiction and expose you to reinstatement or end-of-service claims.
Beneficial ownership: Disclosure expectations differ
One register is publicly searchable. Ownership held confidentially in the other jurisdiction becomes effectively public through the group structure.
Information exchange: Reporting frameworks are not symmetric
Account and entity classification differ between the two regimes; self-certification forms must be prepared separately.
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Figures are indicative and change often. Not legal or tax advice — confirm with qualified counsel.