How to choose a country for IT business operations

Sergiy Barbashyn Attorney, managing partner of Barbashyn Law Firm
7 February, 2025 7 min for reading
7 February, 2025 7 min for reading

Many IT companies operate remotely, engage freelancers/employees, and provide services to clients worldwide. As a result, the need to establish physical offices in different countries is often absent, allowing businesses to operate through any jurisdiction, considering the owners’ preferences and plans.

➡ Here, IT businesses face numerous questions:

costs of incorporation and company maintenance

whether the country suits the business’s specific needs

how to reduce expenses, including taxes

how to open a bank account for transactions

 

It is important to note right away that a “universal” jurisdiction does not exist. When choosing a country for company formation or structuring, it is essential to consider both the characteristics of each country and the needs of your business today and in the near future: tax burden and transparent tax system, intellectual property protection/IP regimes, employees and investors, bank accounts, etc.

Payments and Taxes

For companies with low expenses, a country with minimal corporate income tax rates may be suitable. Notably: Estonia – an attractive 0% corporate income tax, provided that dividends are not distributed. Bulgaria – 10% corporate income tax. Poland – 9% tax on revenue from sales below €2 million.

Intellectual Property Protection and IP Regimes

Typically, IT businesses generate most of their revenue from creating and selling intellectual property rights. To attract and foster the development of IT and creative industries, some countries provide tax reduction opportunities.

For example, Cyprus offers an IP-box regime, allowing companies to reduce the corporate income tax rate by up to 80% of profits. However, this is a rather complex process that requires ongoing product development activities and the physical presence of team members in Cyprus. Similar IP regimes exist in Poland, Luxembourg, Ireland, Portugal, and several other countries.

Employees. Different EU countries have varying income tax rates, ranging from 10-15% (e.g., Bulgaria, Czech Republic, Lithuania) to 50-70% (e.g., Sweden, Germany, Denmark). However, tax rates alone are not always the key factor. Some EU countries impose minimum salary requirements for foreign workers, which can be twice as high as the local minimum wage. Others enforce quotas on foreign employees, limiting their share to 10-20% of the workforce. Apart from tax rates, companies should also consider factors like quality of life, healthcare, and climate when choosing a country.

Investors. Startups are often established with the goal of securing investments for project development—whether from a single investor or multiple sources. As a project grows and secures funding, legal challenges may arise in structuring these investments, such as equity sales, employee stock options, or SAFE agreements. If you are looking for the most flexible jurisdictions for receiving investments and issuing shares, consider:

  • C-Corp in the U.S.

  • LTD in the U.K.

Bank Account. Opening a bank account is not always easy in every country. This is an essential factor, as it is a must-have for certain types of businesses. For example, Google requires sellers to have a bank account in the same country or region where their seller account is registered to receive payments. The list of countries mentioned is not exhaustive, and each case should be analyzed individually.

The above list of countries is not exhaustive and each case should be considered individually.

Which countries to consider for IT in 2025

ESTONIA 🇪🇪

Advantages Key features
  • 0% tax on retained earnings
  • Ease of incorporation and management
  • Crypto-friendly environment
  • Taxation on dividend distribution

  • Challenges in opening a bank account

  • High payroll taxes

THE UK 🇬🇧

Advantages Key features
  • Prestigious jurisdiction status

  • Easy incorporation and management

  • Ability to work with shares

  • Cost of maintenance and taxes

  • Audits for crypto-related activities

  • Visa required for residency

CYPRUS 🇨🇾

Advantages Key features
  • 12.5% Corporate Income Tax (CIT)

  • IP-box regime reducing CIT by up to 80%

  • 0% tax on dividends for non-residents

  • High salaries for employees

  • Cost of registration and maintenance

  • Challenges in opening a bank account

POLAND 🇵🇱

Advantages Key features
  • 9% CIT if revenue < €2 million

  • Relocation opportunities for employees and offices

  • Large territory for warehouses

  • ZUS tax for a single founder

  • Liability for board members

  • Variable tax system

PORTUGAL 🇵🇹

Advantages Key features
  • Special NHR (Non-Habitual Resident) tax regime

  • Convenient migration programs

  • Well-developed living infrastructure

  • High taxes

  • Specific labor law regulations

  • Lengthy migration processes

THE USA 🇺🇸

Advantages Key features
  • Prestigious jurisdiction status

  • Easy incorporation and management

  • Ability to work with shares

  • Geographical location

  • Unconventional tax system

  • Visa required for residency

UKRAINE 🇺🇦

Advantages Key features
  • Simplified tax system and sole proprietorship

  • IT-specialized Diia City regime (5% personal income tax)

  • Large pool of highly qualified professionals

  • Restrictions on foreign currency transactions

  • Underdeveloped investment legislation

Selecting a country for IT business operations is a strategic decision that impacts the company’s future growth, its ability to attract investments, work with international clients, and ensure intellectual property protection. The list of countries above is not exhaustive and should be carefully analyzed on a case-by-case basis.

Before incorporating a company, consider the following questions:

  • How many shareholders and board members will there be?

  • In which countries is the target audience located?

  • Who are the competitors, and which jurisdictions have they chosen?

  • Will the company need to issue shares to attract investment?

  • Who are the company’s clients, and will VAT apply?

  • Are warehouse or office spaces required for business operations?

  • Are stock option agreements necessary to attract top employees?

  • How complex is the registration and maintenance process?

  • Does the company need licenses or permits for its activities?

Published by AIN.UA

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