US LLC for Cyprus residents: Wyoming, New Mexico or Delaware, and the tax trap nobody mentions

General information, not legal or tax advice. Your result depends on your specific facts; ENCC connects you with licensed advisers who confirm it in writing. The figures below are illustrative and are not a promise of tax savings.

Ask ten founders who have just moved to Cyprus what company they plan to use, and at least three will say "a US LLC". The reasons sound convincing. It takes days, not weeks, to form. It costs little to run. It gets you a Stripe US account, a Mercury account and an Amazon seller account with American payouts. The IRS does not tax it if you have no American business. And somebody in a Facebook group has told them that, combined with Cyprus Non-Dom, it means paying nothing at all.

Most of that is true. The last part is where people get hurt. A US LLC is an excellent tool with one very specific weakness for Cyprus residents: nobody can tell you with certainty how Cyprus will classify it. That single question decides whether your profit is taxed as a dividend at 0% SDC for Non-Dom, or as your own business income at progressive rates of up to 35% plus social insurance. This guide walks through that question honestly, explains how to set up and run an LLC properly, what you pay for, what the IRS expects every year, the German angle if you are leaving Germany, and five cases with numbers. At the end you will find the mistakes we see most often and answers to the questions we are asked in almost every first call.

Part 1. What a US LLC actually is

A limited liability company is a creature of US state law. It is formed by filing Articles of Organization with a state, usually Wyoming, New Mexico or Delaware for non-US owners. It has its own legal personality: it can sign contracts, own assets, sue and be sued. Its members are not personally liable for its debts. It is governed by an operating agreement, a private contract among the members that sets out who manages, how profits are allocated and how distributions are made.

That legal flexibility is the point. An LLC can look like a partnership, or like a company with managers and a board, depending on how the operating agreement is drafted. It is also the source of the classification problem, because foreign tax authorities have to decide which of those it resembles.

How the IRS sees it

For US federal tax, a single member LLC is by default a disregarded entity: the IRS treats it as if it did not exist and looks through to the owner. A multi member LLC is by default a partnership. Either can elect to be taxed as a corporation by filing Form 8832, but almost no non-US founder does that, because it would mean paying US corporate tax.

A disregarded LLC owned by a non-US person pays no US federal income tax if it has no income effectively connected with a US trade or business. In practice that means no US office, no US employees, no dependent agent in the US and no US real estate. Selling to American customers online, using Stripe US or holding a US bank account does not by itself create a US trade or business, but a warehouse, staff or an agent concluding contracts in the US can. Check this with a US adviser if your model involves physical presence, inventory in the US or US-based contractors acting for you.

What the IRS still wants every year

Since 2017, a foreign owned disregarded LLC must file Form 5472 with a pro forma Form 1120 each year, reporting transactions between the LLC and its owner (capital contributions, distributions, loans, payments). This applies even if the LLC has no US income. The penalty for failing to file, or filing an incomplete form, is USD 25,000 per form, per year. It is the single most expensive mistake in the US LLC world, and it is entirely avoidable.

Beneficial ownership reporting to FinCEN, which caused anxiety in 2024, no longer applies to companies created in the United States after the 2026 final rule. Your state may still keep its own records of members or managers, and your registered agent will need your identity documents.

Part 2. The Cyprus question: transparent or opaque?

This is the heart of the matter, so it is worth slowing down.

When a Cyprus tax resident owns a foreign entity, Cyprus has to decide whether that entity is a separate taxpayer (opaque) or simply a vehicle through which you earn income yourself (transparent). For a Seychelles IBC or a Cyprus Ltd the answer is obvious: they are companies. For a US LLC it is not.

Cyprus has no published Tax Department circular on how it classifies a US LLC, and advisers split. Many treat a single member LLC as transparent, so the profit is your own business income taxed at progressive rates. Others treat it as an opaque foreign company, so distributions can be dividends (0% SDC for Non-Dom). Plan on the transparent reading, which is the safer base case, and if you want the opaque reading, get a written opinion from a Cyprus tax adviser that cites the LLC's operating agreement (separate legal personality, limited liability, management by managers, distributions only by resolution) and keep that opinion with your return.

If Cyprus treats your directly owned LLC as transparent, it does not pay you a dividend in any meaningful sense: the profit is, in substance, your own business income. You are then effectively self-employed in Cyprus, filing as such, with progressive income tax, social insurance contributions and GESY on that income. Non-Dom does not help, because Non-Dom only covers dividends and interest.

Why the transparent reading is the safer base case

The US itself treats the single member LLC as non-existent for income tax, which makes it easy for a tax inspector to argue that the profit belongs to you.
Many European states classify LLCs through a resemblance test, and a single member LLC managed by its only member resembles a sole proprietorship more than a company.
If you plan for the transparent reading and Cyprus later accepts the opaque one, you have overpaid a little. If you plan for the opaque reading and Cyprus rejects it, you face years of back tax, interest and penalties.

What strengthens the opaque reading

If you want to argue opacity, the operating agreement has to look like a company's constitution, and the LLC has to behave like a company in practice:

Management by appointed managers, not by the member directly.
Profits retained in the LLC until a formal written resolution declares a distribution.
Separate bookkeeping and annual financial statements.
No commingling of LLC and personal funds.
Ideally, more than one member, or an owner that is itself a company (see the Wyoming plus Seychelles structure).

Even then, the reading is an opinion, not a ruling. Keep the written opinion with your return and expect questions.

Management, control and permanent establishment still apply

Suppose Cyprus accepts the opaque reading. Then the LLC is a foreign company, and the ordinary company questions arise. If you, living in Limassol, are the only person managing it, the LLC is managed and controlled from Cyprus and becomes Cyprus tax resident: 15% corporate tax in Cyprus since 1 January 2026. And even an online business can have a permanent establishment in Cyprus if contracts are habitually negotiated and concluded from there. In other words, the opaque reading does not hand you dividend treatment for free. It swaps the classification problem for the management problem.

That is why, for a solo founder living in Cyprus, the honest outcome is usually one of two things. Either you accept the transparent reading and are taxed as self-employed, or you use a Cyprus Ltd and are taxed at 15% plus a Non-Dom dividend. The LLC still has a role: as a US payments vehicle, often under a Cyprus Ltd or a foreign company.

Part 3. Choosing the state

Wyoming

Character: no state income tax, strong privacy, modern LLC statute, very popular with non-US founders
One-off: state filing fee for the Articles of Organization
Annual: annual report license tax due on the first day of the anniversary month, registered agent
Fits: most solo founders and small teams without investors

New Mexico

Character: no annual report, member names not on the public record
One-off: state filing fee
Annual: registered agent only, at state level
Fits: founders who want the lowest running burden; some banks and platforms are less familiar with it

Delaware

Character: the reference corporate law in the US, the Court of Chancery, investor familiarity
One-off: state filing fee
Annual: flat annual franchise tax due 1 June, registered agent
Fits: founders planning to raise money or sell the business to US buyers

The state matters less than people think. The Cyprus classification question, the IRS filings and the management question are the same in all three. Choose by running burden and by what your banks and counterparties prefer.

Official state fees, checked on 14 October 2026

State fees only, as of 14 Oct 2026; agent and provider costs not included.

These are the fees each state itself charges, taken from the official state websites on 14 October 2026. They do not include registered agent, formation service or adviser fees, which vary by provider. States revise their schedules; check the linked page before you file.

Wyoming (Secretary of State, schedule effective 1 July 2026)

Articles of Organization: USD 100
Annual report license tax: USD 60 or 0.0002 of the company's assets located and employed in Wyoming, whichever is greater; due on the first day of the anniversary month
Certificate of good standing: free online via wyobiz.wyo.gov
Source: sos.wyo.gov/Business/Docs/BusinessFees.pdf

Delaware (Division of Corporations)

Certificate of Formation (domestic LLC): USD 110
Annual tax: USD 400 flat, due on or before 1 June for the prior year; no annual report for LLCs
Late payment: penalty of USD 200 plus 1.5% interest per month on tax and penalty
Sources: corpfiles.delaware.gov/Fee_Schedule/AugustFee2026.pdf and corp.delaware.gov/alt-entitytaxinstructions/

New Mexico (Secretary of State)

Articles of Organization: USD 50, filed online only through enterprise.sos.nm.gov
Annual: no annual report and no recurring state fee for a domestic LLC; a registered agent must be maintained
Source: NMSA 1978 § 53-19-63 (fee schedule of the LLC Act) and sos.nm.gov/business-services/

Florida (Division of Corporations, for comparison)

New LLC: USD 125 (filing fee USD 100 plus registered agent designation USD 25)
Annual report: USD 138.75; USD 538.75 if received after 1 May
Source: dos.fl.gov/sunbiz/forms/fees/llc-fees/

Part 4. Step by step: forming and running the LLC

Settle your residence first. Make sure you are Cyprus tax resident (183 days, or the 60-day rule with all its conditions) and that your previous residence is closed and documented. If you form the LLC while still resident in Germany or elsewhere, that country's rules apply to it first.
Write your fact sheet. One page: what you sell, to whom, where the customers are, who negotiates and signs, who delivers, how you are paid. Your Cyprus adviser needs it to give a real answer.
Get the Cyprus tax view in writing. Transparent or opaque, and the consequences for your return. Decide whether you will own the LLC personally, through a Cyprus Ltd or through a foreign company.
Draft the operating agreement deliberately. Not a template downloaded in five minutes. If you want any chance at the opaque reading, use manager management and distributions by resolution.
File the Articles of Organization through a registered agent in the chosen state.
Obtain the EIN from the IRS with Form SS-4. Without a US social security number this is done by fax or through the agent.
Open banking and payments. Mercury, Relay or Wise Business for banking; Stripe US for card payments. State your Cyprus residence correctly: these accounts are reportable.
Keep books from day one. Separate accounts, invoices in the LLC's name, no personal spending from the LLC account.
File every year. Form 5472 and pro forma 1120 to the IRS, the state annual report where required, your Cyprus return reflecting the chosen classification.
Review annually. Rules in Cyprus, the US and the EU change. So does your business.

What you pay for

One-off cost components

State: the filing fee for the Articles of Organization
Service: a formation agent, if you do not file yourself
Documents: a properly drafted operating agreement
Advice: the written Cyprus tax opinion, and a German or other exit review if relevant

Annual cost components

State: annual report or franchise tax, depending on the state
Agent: the registered agent, mandatory in every state
US compliance: preparation of Form 5472 and the pro forma 1120
Cyprus compliance: your Cyprus return, and bookkeeping if you are treated as self-employed
Optional: a US business address, a virtual phone number

Get written quotes. The cheapest formation package is rarely the cheapest structure once the annual filings and advice are counted.

Part 5. Banking and payments

Banking is where the US LLC shines. US fintech banks accept foreign owned LLCs routinely, provided you have an EIN, the formation documents, a passport and a plausible business. Stripe US onboards US LLCs and pays out in USD. Amazon US, Shopify Payments, PayPal Business and most marketplaces work smoothly.

Three cautions. First, FATCA and CRS: US accounts held by a foreign owned entity can be reported, and European EMIs report under CRS. Assume your Cyprus residence is visible and declare everything. Second, fintech banks close accounts at short notice; keep a second payment route. Third, mixing personal and LLC money destroys both your bookkeeping and any argument for opacity.

Part 6. If you are leaving Germany

A large share of the people who move to Cyprus with a US LLC in mind come from Germany. Germany looks at the LLC in its own way.

Classification in Germany

Germany applies a resemblance test (Rechtstypenvergleich) under the Federal Ministry of Finance letter of 19 March 2004. Depending on the operating agreement, an LLC is either a corporation or a transparent partnership for German tax. While you are still German resident, a transparent LLC's profit is simply your business income in Germany; an opaque one can trigger the German CFC rules (§§ 7 to 14 AStG) on passive income below 15% effective tax, and if you manage it from Germany it is a German taxpayer under § 10 AO.

Exit tax

If the LLC is a corporation for German purposes, a holding of at least 1% falls under § 6 AStG exit tax when you leave, provided you were fully German tax resident for at least 7 of the last 12 years. That means tax on the latent gain at departure. The same applies to any GmbH you still hold.

Extended limited tax liability

German nationals who were unlimited taxable in Germany for at least 5 of the last 10 years, move to a country with low taxation (a preferential regime such as Cyprus Non-Dom can count) and keep essential economic interests in Germany can face § 2 AStG extended limited tax liability in the year of departure and the following 10 years. Essential economic interests include German source income above 30% of total income or above EUR 62,000, German assets above 30% or above EUR 154,000, or a German business or a § 17 EStG holding. The rule does not bite in a year where the affected income stays at or below EUR 16,500. Map these tests with a Steuerberater before the move.

The clean sequence is always the same: leave Germany properly, then build. More in Germany to Cyprus, step by step.

Part 7. Four ways to own the LLC

Directly, as an individual

Cyprus view, base case: transparent; profit taxed as your business income, progressive rates up to 35%, social insurance, GESY
Fits: founders whose taxable income is modest, or who accept self-employed taxation in exchange for simplicity
Watch: Form 5472 every year; do not assume dividend treatment

Under a Cyprus Ltd

Cyprus view: the Ltd owns the LLC; if transparent, its profit is the Ltd's profit at 15%; the Ltd then pays you a dividend with 0% SDC for Non-Dom and GESY
Fits: founders who need US payment rails but want predictable Cyprus taxation
Watch: if the LLC were treated as opaque and low taxed, the Cyprus CFC rules can apply to the Ltd

Under a Seychelles IBC

Cyprus view: you receive a dividend from an opaque foreign company; the LLC classification question does not reach you directly
Fits: substantial US revenue, a real director abroad, appetite for two compliance regimes
Watch: the Seychelles multinational group question and the IBC's management; see Wyoming LLC owned by a Seychelles IBC

With several members

Cyprus view: a partnership for the IRS; each member's share follows their own residence
Fits: genuine co-founders in different countries
Watch: the LLC must file a US partnership return (Form 1065) and may have withholding obligations if it has US effectively connected income

Part 8. Five cases with numbers

The people are fictional and the numbers simplified: one Cyprus Non-Dom resident, no other income, all profit taken in the same year. The calculations show taxes, not service prices. They are not offers or promises of savings.

Ollie, 31, Shopify store owner, formerly Bristol

Business: ecommerce selling to US customers through Shopify and Stripe US
Annual profit: EUR 60,000
Structure: Wyoming LLC owned directly
Cyprus treatment: transparent; he registers as self-employed and declares the profit
Tax: progressive income tax on EUR 60,000 plus social insurance and GESY
Lesson: the LLC solved his payment problem, not his tax position; he is taxed like any self-employed Cyprus resident, and that is fine

Ana, 37, SaaS founder, formerly Porto

Business: subscription software, 60% US customers, EUR 180,000 profit
Structure: Delaware LLC under a Cyprus Ltd
Tax: EUR 27,000 corporate tax at 15% in the Ltd; dividend of EUR 153,000 with 0% SDC for Non-Dom; GESY of 2.65% only up to the EUR 180,000 cap on total income, about EUR 4,050
Lesson: predictable, bankable, defensible; Stripe US through the LLC, European banking through the Ltd

Lukas, 43, consultant, German national, formerly Stuttgart

Business: IT consulting, mostly German clients, EUR 120,000 profit
Temptation: a Wyoming LLC and "Non-Dom, no tax"
Problems: German clients and German source income, a let flat in Stuttgart, § 2 AStG exposure; the LLC managed by him in Limassol; Cyprus transparent reading
Right path: Steuerberater review of § 2 AStG first; sell or restructure German interests; then a Cyprus Ltd
Lesson: an LLC does not move German source income out of Germany's reach

Priya, 35, course creator, formerly Dublin

Business: online courses sold worldwide, EUR 40,000 profit
Structure: New Mexico LLC owned directly, transparent in Cyprus
Tax: progressive income tax on EUR 40,000, social insurance, GESY
Lesson: at this level the simplest structure wins; a second company would cost more than any difference it could make

Mihai and Tom, co-founders in Cyprus and Canada

Business: developer tools, two members, 50/50
Structure: Delaware LLC, partnership for the IRS
Tax: each declares his share in his own country; Mihai, as a Cyprus resident, on the transparent reading as business income
Lesson: a multi member LLC is a partnership in the US; file Form 1065 and get advice in both residence countries

Part 8b. EUR 100,000 of LLC profit, four ways (illustrative)

Same business, same profit, four ownership choices. Taxes and contributions only; the cost of running each structure comes on top and grows with the number of layers.

LLC owned directly, transparent reading

What Cyprus taxes: EUR 100,000 as your business income
Taxes: progressive income tax with a 35% top marginal rate, self-employed social insurance up to the insurable earnings ceiling, GESY on the income
Result: usually the heaviest tax bill of the four, but the lightest compliance

LLC owned directly, opaque reading with a written opinion and real management abroad

What Cyprus taxes: the dividend you take
Taxes: 0% SDC for Non-Dom, about EUR 2,650 GESY on a EUR 100,000 distribution
Result: attractive on paper; in practice rare for a solo founder living in Cyprus, because the LLC would be managed from Cyprus and taxed there at 15%

LLC under a Cyprus Ltd

What Cyprus taxes: EUR 100,000 in the Ltd, then the dividend
Taxes: EUR 15,000 corporate tax, then about EUR 2,250 GESY on the EUR 85,000 dividend, 0% SDC for Non-Dom; around EUR 17,250 in total
Result: the most predictable outcome, with European banking alongside US rails

LLC under a Seychelles IBC with a real director abroad

What Cyprus taxes: the IBC's dividend to you
Taxes: 0% SDC for Non-Dom, about EUR 2,650 GESY
Result: only holds with genuine management outside Cyprus, no Cyprus permanent establishment and a Seychelles counsel letter on the group question; otherwise 15% in Cyprus plus interest and penalties

Assumptions: one Cyprus Non-Dom, all profit distributed in the year, no other income, no German or other foreign tax claim remaining. Not an offer and not a promise of savings.

The pattern is clear. The more a structure promises, the more it depends on facts that a solo founder living in Cyprus rarely has: a real director abroad, contracts concluded abroad, a team. Choose the line that matches your facts today, not the one that matches the brochure.

Part 9. Cyprus tax points you will meet

Corporate rate

From 1 January 2026, the Cyprus corporate income tax rate is 15% (Law 244(I)/2025). Any calculation using an older rate is out of date.

Non-Dom and SDC

0% SDC on dividends and interest for Non-Dom, for up to 17 of 20 years. GESY of 2.65% applies to dividends, capped on income of EUR 180,000. Non-Dom does not cover business income, salary or self-employment income.

CFC rules

Since 2019, based on the EU Anti Tax Avoidance Directive, the Cyprus CFC rules apply to Cyprus resident companies controlling low taxed foreign entities. They do not attribute income to individuals. If a Cyprus Ltd owns your LLC and the LLC were treated as an opaque low taxed entity, the rules need checking.

Defensive measures

Cyprus applies withholding taxes on payments by Cyprus companies to affiliates in jurisdictions on Annex I of the EU list. The United States is not on the list, but some US territories (American Samoa, Guam, the US Virgin Islands) are on Annex I as of October 2026. A US LLC formed in a state is not affected.

Permanent establishment

An online business can have a permanent establishment in Cyprus. Whatever the classification, if you run the business from your home in Cyprus, Cyprus has a claim on the profit.

Part 9b. US state taxes, sales tax and other surprises

Federal income tax is not the only US tax question. Three others regularly surprise non-US owners.

Sales tax

The US has no federal VAT, but most states levy sales tax, and since the Supreme Court's Wayfair decision in 2018 a seller can owe sales tax in a state without any physical presence there, once its sales into that state cross the state's economic nexus threshold. For digital products and physical goods sold to US consumers, this can matter even for a small store. Marketplaces such as Amazon and Etsy usually collect and remit for you; your own Shopify or Stripe checkout usually does not. Check your sales by state each year and register where needed.

State income and franchise taxes

Wyoming has no state income tax, and neither do several other states, but a state where you have nexus can claim franchise or income tax. California, for example, is known for asserting its minimum franchise tax on LLCs doing business there. A non-US owner who sells online without US presence rarely meets this, but a US warehouse, a US employee or a co-founder living in the US can change it.

Withholding on US source income

If your LLC receives US source passive income, such as US dividends or certain royalties, withholding of up to 30% can apply at source, reduced by treaty where you can claim one. Cyprus and the US have a tax treaty, but a disregarded LLC claims treaty benefits through its owner. Get this right before you put a US investment portfolio inside an LLC.

Part 9c. What your year looks like in practice

Founders often ask what running an LLC from Cyprus feels like across a full year. Here is a typical calendar for a directly owned, transparent LLC.

January to March

US: close the books for the previous year; your accountant prepares Form 5472 and the pro forma 1120, normally due 15 April with an extension available
State: diary the annual report due date in your anniversary month (Wyoming) or the franchise tax (Delaware, 1 June)
Cyprus: collect the LLC's profit and loss for your self-employed return

April to July

US: file Form 5472 or the extension; check sales tax registrations
Cyprus: provisional tax and social insurance payments as self-employed; prepare the annual return

August to December

Cyprus: submit the personal return within the deadline set for the year
Review: check whether your profit level still justifies the structure, and whether a Cyprus Ltd on top would now make sense

For an LLC under a Cyprus Ltd, add the Ltd's own calendar: bookkeeping, statutory audit, corporate tax return, the annual return to the registrar, dividend resolutions and the GESY on dividends.

Part 9d. When to stop using the LLC

An LLC is easy to start and equally easy to keep longer than it deserves. Signs it is time to restructure or close it:

Your US revenue has dropped and the LLC is only an extra layer of filings.
You now have a Cyprus Ltd that could hold the payment accounts directly through European providers.
Your fintech bank or Stripe account was closed and the LLC no longer gives you access to US rails.
You plan to sell the business and buyers prefer a corporation or a European entity.
You plan to leave Cyprus and your next country treats LLCs badly.

Closing properly means filing Articles of Dissolution with the state, a final Form 5472, closing the EIN account with the IRS by letter, and documenting in Cyprus where the assets went. An LLC simply abandoned keeps generating state fees, penalties and, eventually, a revoked status that can follow you when you apply for banking elsewhere.

Moving the LLC under another owner

Instead of closing, many founders contribute their LLC to a new Cyprus Ltd. That is a transfer of an asset from you to your company, with possible tax consequences in Cyprus depending on how the LLC is classified and what it is worth. Get the valuation and the Cyprus opinion before you sign the assignment of membership interest, and remember the Ltd's first Form 5472 obligations as the LLC's new foreign owner.

Part 10. The mistakes we see most often

Assuming dividend treatment. Without a written opinion, plan on business income.
Missing Form 5472. USD 25,000 per form per year, even with zero US income.
A template operating agreement. It decides classification arguments; draft it deliberately.
Commingling funds. Paying rent and groceries from the LLC account.
Forming before leaving. Your former country's rules reach the LLC first.
Ignoring US presence. US staff, warehouses or agents can create a US trade or business and US tax.
Believing the LLC is invisible. FATCA, CRS and payment processors all report.
Calculating with an outdated Cyprus rate. It is 15% for 2026.
Using the LLC for German source income. § 2 AStG and German source rules still apply.
No second payment route. Fintech accounts can be closed with little notice.

Part 11. Frequently asked questions

Does a US LLC pay tax in the US?

A single member LLC owned by a non-US person with no US trade or business generally pays no US federal income tax. State taxes and fees still apply, and Form 5472 must be filed.

Is my LLC profit a dividend in Cyprus?

Not by default. With no official Cyprus position, plan on it being your business income; rely on dividend treatment only with a written opinion from a Cyprus adviser.

Can I combine an LLC with Non-Dom?

Yes, but Non-Dom only helps with dividends and interest. If the LLC is transparent, Non-Dom does not touch the profit.

Which state is best?

Wyoming or New Mexico for most solo founders, Delaware if you expect investors. The Cyprus tax question is the same in all three.

Do I need a US address or phone number?

You need a registered agent address in the state. A business address is optional but helps with some banks and platforms.

Can I get an EIN without a US social security number?

Yes, with Form SS-4 submitted by fax or through your agent.

Will Cyprus know about my LLC?

Assume yes. US and European financial institutions report under FATCA and CRS. Declare everything.

Can I pay myself a salary from the LLC?

From a transparent LLC there is nothing to pay; the profit is already yours. From an opaque one, a salary is taxed in Cyprus as employment income.

Should my Cyprus Ltd own the LLC?

Often that is the most defensible way to use US payment rails as a Cyprus resident: the profit is taxed at 15% in Cyprus and reaches you as a Non-Dom dividend.

Does the LLC protect my assets?

It limits liability for business debts if you respect the separation between you and the LLC. It does not protect against taxes you owe personally.

What if I leave Cyprus later?

The LLC moves with you; its classification and taxation then follow your new country's rules. Plan the move like any other.

I am German. What changes?

Germany classifies the LLC itself, can apply exit tax under § 6 AStG if it is a corporation for German purposes, and can apply § 2 AStG after your departure if you keep essential economic interests in Germany. See a Steuerberater before the move.

Is a US LLC a good idea below EUR 50,000 profit?

As a payments vehicle owned directly and taxed transparently, it can be. As a tax structure, rarely.

The ENCC view

A US LLC is one of the best tools there is for getting paid by the world. It is not, by itself, a tax plan for a Cyprus resident. Treat it as payment infrastructure, decide honestly how Cyprus will see it, and pair it with the structure that matches your real life: self-employed if you are small and solo, a Cyprus Ltd if you want predictability, a foreign company with real management abroad if your business genuinely has it. ENCC prepares your fact sheet and connects you with licensed US formation agents and Cyprus tax advisers who confirm the setup in writing.