Canadian LLP/LP vs US LLC (Portugal NHR)

ska

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May 28, 2025
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Hello, I'm under the NHR in Portugal. I'm trying to understand pros/cons of US LLC vs Canadian LLP/LP (Ontario and British Columbia)

almost everyone under the NHR goes with an US LLC (reaching the 0% tax rate)
I know I know, grey area, but for now the Portuguese tax authorities have never disputed anything.

but I would prefer to incorporate a Canadian company (instead of the classic US LLC): in my mind it has higher reputation.
Maybe it would be also better as they're less popular as they aren't usually on tax authorities radars.

Are there other cons I haven't though about? Would it be easy to open bank accounts (EMIs and physical)?

all my transactions are in euro, so maybe it doesn't even matter the canadian/us bank (?) or do they have multicurrency accounts with iban too?
if not, are there international or europan banks that they will let me open a business bank account for the canadian/us company?

Thanks
 
The only difference is whether Portugal determines an LLC to be a corporation or a partnership. If they say it's a partnership, then tax treatment is very likely the same as income from an LP/LLP.

ska said:
Are there other cons I haven't though about? Would it be easy to open bank accounts (EMIs and physical)?
Click to expand...
Company type and place of incorporation are just two of many, many factors that affect the prospect of opening a bank account.

A BVI company holding shares in a Japanese supermarket chain: low/medium risk.
A US LLC involved in extraction mining in Central African Republic: high risk.

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This is the probably the answer to your question.
 

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