For residents of Cyprus who own a US LLC
US LLC Owned From Cyprus: Form 5472, Taxes and Filing
You live in Cyprus and own a US LLC. Each year it files Form 5472 with a pro forma Form 1120, even with no US income, and the US has an income tax treaty with Cyprus. This page covers what to file, what to enter as your foreign tax ID, and what the treaty position means for you.
Quick answer
Does an LLC owned from Cyprus file with the IRS every year?
In most cases. Form 5472 with a pro forma Form 1120 is due for any year the LLC had a transaction with you, which includes funding it. Profit is not required. The filing identifies you as the foreign owner living in Cyprus, and since the US has a treaty with Cyprus, treaty rules can limit US tax on profits.
At a glance
- Yearly US filing
- Form 5472 with a pro forma Form 1120
- US tax treaty with Cyprus
- Yes, per the IRS treaty list
- Your home tax ID
- 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
- Currency
- Convert euros to US dollars; the form is in US dollars
- Fees
- See our Form 5472 filing service page, or request a quote
What the US treaty with Cyprus does for an LLC owner
Because Cyprus has an income tax treaty with the United States (IRS treaty list), an owner there has two tools that owners in non-treaty countries do not.
The permanent establishment test. Under US treaties, a resident's business profits are generally taxable in the US only when attributable to a permanent establishment there. An LLC run from Cyprus with no US office or dependent agent may have none. If a return relies on that, Form 8833 discloses it, and leaving it out can cost US$1,000 (IRS).
Treaty withholding on Form W-8BEN. For US-source dividends, interest or royalties paid to you, a treaty claim on Form W-8BEN naming Cyprus gets the treaty rate instead of the general 30% (IRS, IRS).
Neither tool changes Form 5472, which is due either way.
Does an LLC owned from Cyprus owe a US filing with no income?
The yearly filing for an LLC owned from Cyprus is mostly an information return. The LLC usually pays no US income tax as a disregarded entity, but the IRS still wants a record of money and property moving between the LLC and its foreign owner. So the LLC files Form 5472 with a pro forma Form 1120, normally by April 15 for a calendar year, and a missed or substantially incomplete form carries a US$25,000 penalty (IRS).
Two other filings sit around it. Right after formation, a BE-13 is generally due within 45 days (BEA rule). Each year, the formation state has its own report or fee (fees by state). A Form 1040-NR comes in only if the LLC has income effectively connected with a US trade or business (IRS).
Documents for owners living in Cyprus
Most of what goes into the filing comes from the LLC's own records. The parts that come from you, as an owner living in Cyprus, are short.
| Item | For an owner in Cyprus |
|---|---|
| Identity | Passport and current home address |
| Tax ID | 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 |
| Money in and out | Statements showing what you paid into the LLC and took out during the year, including amounts in euros |
| Company papers | Articles of organization and the IRS EIN letter |
For a resident of Cyprus, this is usually 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 (OECD tax ID sheet).
Your taxes in Cyprus
Founders based in Cyprus use a US LLC for trading, software and investment-related businesses with US customers.
How the LLC's profit is taxed in Cyprus is decided under the tax rules of Cyprus, which can treat a US LLC differently from the way the IRS does. Check that with a tax adviser in Cyprus. We handle the US side and can give your adviser the US figures and filings.
Filing from Cyprus with us
For an owner in Cyprus, we prepare the Form 5472 and pro forma Form 1120 filing, or the full year for a single-member LLC. Gurleen Kaur, CPA (BC and Washington), prepares and signs. See our Form 5472 filing service for fees, or request a quote.
See our Form 5472 filing service, the annual compliance package and which state to form in.
Treaty and US law sources
Where each rule on this page comes from, for an owner resident in Cyprus.
Treaty
- The IRS lists the 1984 income tax treaty. General effective date (IRS Table 3): treaty Jan. 1, 1986 (IRS treaty documents for Cyprus; treaty text; IRS Table 3).
- Article 3 (Fiscal Residence), which decides who counts as a resident for treaty benefits.
- Article 9 (Permanent Establishment), which defines a US permanent establishment.
- Article 8 (Business Profits), under which business profits are taxed in the US only if attributable to a permanent establishment.
- Article 12 (Dividends), on dividends.
- Article 13 (Interest), on interest.
- Article 14 (Royalties), on royalties.
- Article 26 (Limitation on Benefits), which sets the tests a resident must meet to claim benefits.
- Article 5 (Relief from Double Taxation), on relief from double taxation.
- Treaty benefits for income earned through a fiscally transparent entity, such as a single-member LLC, are decided under section 894 and Treas. Reg. section 1.894-1(d) (IRS Pub 515, Form 8833).
US law
- Form 5472: Internal Revenue Code section 6038A and Treas. Reg. section 1.6038A-1; final regulations T.D. 9796 treat a foreign-owned US disregarded entity as a corporation for this purpose (IRS Form 5472 instructions).
- US trade or business and effectively connected income: Code sections 864 and 871 (IRS Pub 519).
- Treaty disclosure: Code section 6114, Treas. Reg. section 301.6114-1, and the section 6712 penalty (IRS Form 8833).
- BE-13: 15 CFR 801.7 (eCFR).
The tax law of Cyprus itself also applies to you; check it with a local adviser.
Owners in other countries
Every country page uses the same US rules with that country's treaty status and tax ID. See all of them on US LLC tax by country.
- The Netherlands
- Turkey (Turkiye)
- Romania
- China
- Argentina
- Brazil
- The United Kingdom
- Germany
- India
- Pakistan
- The United Arab Emirates
- South Africa
- Australia
- Panama
- Peru
- Greece
- Italy
- Spain
- France
- Nigeria
- Mexico
- The Philippines
- Poland
- Portugal
- Israel
- Japan
- South Korea
- Thailand
- Ireland
- Switzerland
- Sweden
- Austria
- Belgium
- Denmark
- Norway
- New Zealand
- Singapore
- Hong Kong
- Malaysia
- Colombia
- Kenya
- Ghana
- Saudi Arabia
- Vietnam
- Chile
- The Czech Republic
- Finland
- Iceland
- Estonia
- Latvia
- Lithuania
- Slovakia
- Slovenia
- Indonesia
- Ukraine
- Egypt
- Bangladesh
- Morocco
- Sri Lanka
- Bulgaria
- Malta
Common questions
Does a resident of Cyprus have to file Form 5472 for a US LLC?
Yes, if the single-member LLC had a reportable transaction with you in the year, which includes forming it and putting money in. It is filed with a pro forma Form 1120. The penalty for not filing is US$25,000.
Which tax ID from Cyprus do you need from me?
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 IRS asks for the same foreign tax ID every year.
Does the United States have a tax treaty with Cyprus?
Yes. Cyprus is on the IRS list of US income tax treaties. The treaty can limit US tax on business profits to profits attributable to a US permanent establishment, a position disclosed on Form 8833, and lets you claim treaty rates on Form W-8BEN.
Does an LLC owner in Cyprus file a US income tax return?
Usually only Form 5472 with the pro forma Form 1120 is filed. A Form 1040-NR is needed if the LLC has income effectively connected with a US trade or business, and the treaty may limit US tax to profits attributable to a US permanent establishment.
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 5472
- IRS: Form 8833, treaty-based return position disclosure
- IRS: Instructions for Form W-8BEN
- eCFR: 15 CFR 801.7 (BE-13 reporting requirement)
- OECD: Information on tax identification numbers, Cyprus
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, US LLC tax by country.
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