For non-US residents who own a US LLC
US LLC Tax by Country: Form 5472, Treaties and Foreign Tax IDs
The US filing for a foreign-owned single-member LLC is the same wherever you live: Form 5472 with a pro forma Form 1120. Two things change with your country: whether the US has an income tax treaty with it, and which tax ID you put on Form 5472. Pick your country below.
Quick answer
Does the US filing for a foreign-owned LLC depend on the owner's country?
The core filing does not: every foreign-owned single-member US LLC with a reportable transaction files Form 5472 with a pro forma Form 1120, with a US$25,000 penalty if it is missed. Your country decides whether a US tax treaty applies, which affects how business profits and US-source payments are taxed, and which home-country tax ID you report.
At a glance
- Who it is for
- Non-US residents who own a single-member US LLC
- Same in every country
- Form 5472 with a pro forma Form 1120 each year; US$25,000 penalty if missed
- What differs
- US tax treaty status and the foreign tax ID on Form 5472
- Countries covered
- 62 so far, 48 with a US income tax treaty
- Fees
- See our Form 5472 filing service page, or request a quote
Pick your country
Treaty status is from the IRS list of US income tax treaties, and tax ID names are from the OECD tax identification number sheets, both checked November 11, 2026.
| Country | US tax treaty | Home-country tax ID |
|---|---|---|
| Argentina | No | The tax identification number issued to you in Argentina |
| Australia | Yes | Your Tax File Number (TFN) issued by the Australian Taxation Office |
| Austria | Yes | The tax number issued by your local tax office; Austria issues it only to individuals who are liable to tax |
| Bangladesh | Yes | The tax identification number issued to you in Bangladesh |
| Belgium | Yes | Your 11-digit Belgian identification number |
| Brazil | No | Your CPF (Cadastro de Pessoas Fisicas) number, Brazil's tax identification number for individuals |
| Bulgaria | Yes | The tax identification number issued to you in Bulgaria |
| Chile | Yes | Your RUT (Rol Unico Tributario) |
| China | Yes | The number on your Chinese Resident Identity Card, which serves as your tax identification number |
| Colombia | No | Your NIT (Numero de Identificacion Tributaria), assigned by DIAN |
| Cyprus | Yes | Your TIN if you are obliged to register for tax; Cyprus does not issue TINs to individuals who are not, and the IRS allows "None" in that case |
| The Czech Republic | Yes | Your Personal Identification Number; the Czech Republic issues a separate tax number only to individuals who must register for tax, such as VAT payers |
| Denmark | Yes | Your CPR number, which Denmark uses as the tax identification number for individuals |
| Egypt | Yes | The tax identification number issued to you in Egypt |
| Estonia | Yes | Your Estonian personal identification code |
| Finland | Yes | Your Finnish personal identity code (social security number) |
| France | Yes | Your numero fiscal de reference (SPI number), the tax identification number the French tax authorities give every individual with a French tax obligation |
| Germany | Yes | Your tax identification number (Steuer-ID), issued for life by the Federal Central Tax Office (Bundeszentralamt fur Steuern) |
| Ghana | No | Your Taxpayer Identification Number issued by the Ghana Revenue Authority |
| Greece | Yes | The taxpayer identification number the Greek Tax Administration assigns to every taxpayer |
| Hong Kong | No | Your Hong Kong Identity Card (HKID) number, which serves as the equivalent of a TIN because Hong Kong does not issue a separate one |
| Iceland | Yes | Your kennitala (Icelandic Identification Number) |
| India | Yes | Your Permanent Account Number (PAN), the 10-character tax identification number issued by the Income Tax Department |
| Indonesia | Yes | Your NPWP (Nomor Pokok Wajib Pajak) |
| Ireland | Yes | Your Personal Public Service Number (PPS No), which the Revenue Commissioners use to identify taxpayers |
| Israel | Yes | Your Israeli ID number, which serves as the tax identification number for individuals |
| Italy | Yes | Your codice fiscale, Italy's tax identification number |
| Japan | Yes | Your Individual Number (My Number), the 12-digit number assigned under Japan's Social Security and Tax Number System |
| Kenya | No | Your KRA PIN (Personal Identification Number), which serves as your tax identification number |
| Latvia | Yes | The tax identification number issued to you for tax administration in Latvia |
| Lithuania | Yes | Your Lithuanian personal code |
| Malaysia | No | Your Tax Identification Number (Nombor Pengenalan Cukai) from the Inland Revenue Board of Malaysia |
| Malta | Yes | Your Identity Card Number if you are a Maltese national, or the 9-digit taxpayer reference number issued by the Inland Revenue Department |
| Mexico | Yes | Your RFC (Registro Federal de Contribuyentes) from the Mexican Tax Administration Service (SAT) |
| Morocco | Yes | The tax identification number issued to you in Morocco |
| The Netherlands | Yes | The Citizen Service Number (BSN), a 9-digit number the Netherlands uses as its tax identification number |
| New Zealand | Yes | Your IRD number issued by Inland Revenue |
| Nigeria | No | Your Taxpayer Identification Number (TIN), issued by your State Board of Internal Revenue or by the Federal Inland Revenue Service |
| Norway | Yes | Your national identity number, or a D-number if you were given one as a foreign national |
| Pakistan | Yes | Your CNIC number, which Pakistan uses as the National Tax Number (NTN) for individuals |
| Panama | No | Your RUC (Registro Unico de Contribuyente), which for an individual is the same as the personal identity number |
| Peru | No | Your RUC (Registro Unico de Contribuyentes) number from SUNAT |
| The Philippines | Yes | The tax identification number issued to you in the Philippines |
| Poland | Yes | Your PESEL number, which Poland treats as the tax identification number for individuals who do not run a registered business or file VAT; if you do, use the tax identification number issued for that |
| Portugal | Yes | Your Portuguese tax identification number issued by the Tax and Customs Authority |
| Romania | Yes | The Personal Numerical Code (CNP), which the Romanian tax administration uses as the tax identification number for individuals |
| Saudi Arabia | No | The tax identification number issued to you in Saudi Arabia |
| Singapore | No | Your NRIC number if you are a citizen or permanent resident, or your FIN if you are a foreign individual with a work pass |
| Slovakia | Yes | Your TIN if you are registered for business with a local tax office; most individuals in Slovakia do not have one, and the IRS instructions allow "None" when there is no foreign tax ID |
| Slovenia | Yes | The tax identification number issued to you in Slovenia |
| South Africa | Yes | Your income tax reference number issued by the South African Revenue Service (SARS) |
| South Korea | Yes | Your Resident Registration Number, which Korea uses as the tax identification number for individuals |
| Spain | Yes | Your Spanish tax identification number; for Spanish nationals this is generally the number on the national identity card (DNI) |
| Sri Lanka | Yes | The tax identification number issued to you in Sri Lanka |
| Sweden | Yes | Your personal identity number (personnummer), or a co-ordination number if you are not in the Swedish population register |
| Switzerland | Yes | Your Old-Age and Survivors' Insurance (AHV/AVS) number, which Switzerland designates as the tax identification number for individuals |
| Thailand | Yes | Your 13-digit Tax Identification Number |
| Turkey (Turkiye) | Yes | The National Identity Number, which Turkiye uses as the tax identification number for its citizens |
| Ukraine | Yes | The tax identification number issued to you in Ukraine |
| The United Arab Emirates | No | The UAE generally does not issue personal tax IDs; the IRS accepts "None" when there is no foreign tax ID |
| The United Kingdom | Yes | Your Unique Taxpayer Reference (UTR), the 10-digit number HMRC gives to anyone who files a tax return; the National Insurance number is the other number the UK treats as a tax identifier |
| Vietnam | No | The tax identification number issued to you in Vietnam |
What is the same everywhere
A single-member US LLC owned by a non-US person is treated as a corporation for Form 5472 purposes. It files Form 5472 with a pro forma Form 1120 every year it has a reportable transaction with its owner, including the money used to form and fund it, and the penalty for not filing is US$25,000 (IRS). A BE-13 is generally due within 45 days of setting up or buying a US business (BEA rule). State fees depend on the state; see US LLC annual fees by state.
What the treaty changes
With a treaty, business profits are generally taxed in the US only if attributable to a US permanent establishment, a position disclosed on Form 8833 (IRS), and you can claim treaty rates on Form W-8BEN (IRS). Without a treaty, US tax on the LLC's profit depends only on whether the income is effectively connected with a US trade or business, and US-source dividends, interest and royalties are generally withheld at 30% (IRS).
How we help
We prepare Form 5472 with the pro forma Form 1120, or the full year for a single-member LLC. Gurleen Kaur, CPA licensed in British Columbia and Washington State, signs. Fees are on our Form 5472 filing service; request a quote below. All forms we handle: forms we prepare.
Common questions
Which countries have a US income tax treaty?
The IRS keeps the list on its page United States income tax treaties, A to Z. Of the countries on this page, Argentina, Brazil, The United Arab Emirates, Panama, Peru, Nigeria, Singapore, Hong Kong, Malaysia, Colombia, Kenya, Ghana, Saudi Arabia, Vietnam have no treaty.
What if my country does not issue a tax ID?
The IRS instructions allow "None" or "N/A" when an owner has no foreign tax ID. The United Arab Emirates, for example, generally does not issue tax identification numbers to individuals.
Is Form 5472 required if the LLC had no income?
Yes, if it had a reportable transaction with its owner, such as money put in to form or fund it. The penalty for not filing is US$25,000.
Sources
Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.
- IRS: United States income tax treaties, A to Z
- IRS: Instructions for Form 5472
- IRS: Form 8833, treaty-based return position disclosure
- IRS: Instructions for Form W-8BEN
- IRS: Publication 515, withholding on nonresident aliens and foreign entities
- eCFR: 15 CFR 801.7 (BE-13 reporting requirement)
Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 11, 2026. This page is general information, not tax or legal advice for your situation.
Related guides: Form 5472 filing service, Annual compliance package, Best state for non-US founders.
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