US LLC vs Estonian OÜ vs UAE Company: Annual Filing Burden

A foreign-owned US single-member LLC files Form 5472 with a pro forma Form 1120 to the IRS, by fax or mail, for each year it has a reportable transaction with its owner. An Estonian OÜ files an annual report with the Estonian business register within six months of year-end. A UAE free-zone company registers for UAE corporate tax and files a return within nine months of its tax period.

Digital nomads usually compare these three vehicles on tax rates. This post compares something narrower: the paperwork each one generates every year, who receives it, and when it is due. It does not compare tax outcomes, personal filings or setup costs, and it does not rank the structures — that depends on where you live and what your advisers say.

Each entity has a fixed annual cycle that runs whether or not the business made money. If you own a US LLC, we prepare and fax the complete Form 5472 package from $149; the Estonian and UAE sides need a local accountant. We describe those in outline only, from each government's own pages, and where we found no official statement the table says "varies — check" and names the authority.

What does each entity file every year?

Each entity reports to a different authority on a different clock. The table assumes a calendar financial year.

Entity	Where it files	Annual return or report	Accounts / audit	Key deadline	Source
US single-member LLC, foreign owner	IRS, by fax or mail; plus the state of formation	Form 5472 with a pro forma Form 1120; state report or tax — varies, check your state	No federal audit requirement; state items vary — check your state's filing office	April 15 for a calendar-year entity; Form 7004 extends it	IRS Instructions for Form 5472
Estonian OÜ (private limited company)	County court registration department, via the e-Business Register	Annual report, required even with no economic activity	Audit or review only above statutory thresholds — varies, check RIK	Within six months of the financial year-end (30 June for a calendar year)	RIK: Annual report
Estonian OÜ paying a dividend	Estonian Tax and Customs Board	Form TSD with Annex 7, and form INF 1	Not applicable	By the 10th day of the month after the dividend is paid	EMTA: Taxation of dividends
UAE free-zone company (corporate tax)	Federal Tax Authority (FTA)	Corporate tax registration, then a return per tax period	Audited statements for every Qualifying Free Zone Person, and above AED 50,000,000 revenue (tax periods from 1 January 2025)	Return and payment within nine months of the end of the tax period	Ministry of Finance: Corporate tax; Ministerial Decision No. 84 of 2025
UAE free-zone company (free-zone authority)	The free zone that issued the licence	Licence renewal and any accounts submission	Varies by free zone — check your free-zone authority	Varies by free zone — check your free-zone authority	Varies — check your free-zone authority

What does a foreign-owned US LLC file each year?

A single-member LLC owned by a non-US person files Form 5472 attached to a pro forma Form 1120 for each tax year in which it had a reportable transaction with its owner or another foreign related party. Under Treas. Reg. § 1.6038A-1, for tax years beginning on or after 1 January 2017 and ending on or after 13 December 2017, a foreign-owned US disregarded entity is treated as a corporation separate from its owner solely for these reporting rules.

The pro forma Form 1120 carries "Foreign-owned U.S. DE" across the top of page 1; only the LLC's name and address and items B and E are required.
It cannot be e-filed. It goes by fax or mail; the steps are below.
The due date is generally April 15 for a calendar-year entity. Form 7004 extends it — see our Form 5472 extension guide.
Reportable transactions are contributions, distributions, loans either way and payments for goods or services between you and the LLC. A Stripe or Wise payout from a client is not one; moving that money to your personal account is. See our reportable transactions examples.

The IRS instructions state that a $25,000 penalty may apply for failure to file when due and in the prescribed manner, failure to maintain required records, or a substantially incomplete Form 5472, which counts as a failure to file. It is not automatic for every mistake.

State requirements depend on where the LLC was formed: some states want an annual report, some an annual tax or fee. Check your state's filing office.

What does an Estonian OÜ file each year?

An Estonian private limited company (osaühing, OÜ) must submit an annual report to the registration department of the county court, through the e-Business Register. The Centre of Registers and Information Systems states that the report and the documents submitted with it are due within six months of the end of the financial year — 30 June for a company whose year ends on 31 December.

Three points from the RIK annual report page matter most for an owner abroad:

Dormancy does not excuse it. The report is due even if there was no economic activity.
Late filing is enforced. The registrar may fine the company and the persons obliged to submit without warning; six months beyond the deadline, a supervisory procedure can end in deletion from the register or compulsory dissolution.
Audit is threshold-based. The page refers to the thresholds in Estonia's auditing legislation rather than imposing a universal audit — check with RIK or your Estonian accountant.

Tax reporting runs separately with the Estonian Tax and Customs Board. When a resident company pays a dividend, EMTA states that it declares and pays the income tax on form TSD Annex 7 and form INF 1 by the 10th day of the following month (EMTA: Taxation of dividends). Other returns — salaries, VAT — depend on what the company does; your Estonian accountant will know which apply.

e-Residency, through which many OÜs are formed, is a digital identity, not tax residency and not a company; it changes none of these filings or any US filing. Our Estonia and e-Residents guide covers that confusion.

What does a UAE free-zone company file each year?

A UAE free-zone company answers to federal corporate tax, which is uniform, and to its free-zone authority, which is not.

Federal corporate tax. The UAE Ministry of Finance states that all taxable persons, including free-zone entities, must obtain a Corporate Tax Registration Number from the Federal Tax Authority, and must file a return and pay any tax due within nine months of the end of the relevant tax period. A Qualifying Free Zone Person can benefit from a 0% rate on qualifying income, but still registers and files.

Registration timing. Under FTA Decision No. 3 of 2024, a resident juridical person, including a free-zone person, incorporated on or after 1 March 2024 must apply to register within three months of incorporation (FTA announcement). The FTA states that late registration attracts administrative penalties.

Audited financial statements. Ministerial Decision No. 84 of 2025 requires audited financial statements, for tax periods starting on or after 1 January 2025, from a non-group taxable person with revenue above AED 50,000,000 and from every Qualifying Free Zone Person, regardless of revenue.

Free-zone authority requirements. Licence renewal, and whether accounts must also be lodged with the free zone, are set by each free zone. We found no single official source covering them all: varies by free zone — check your free-zone authority.

For what a UAE-based owner puts in the US FTIN box, see our UAE and Dubai residents guide.

When do the deadlines fall in a calendar year?

For a 31 December year-end, the recurring deadlines fall as follows.

Month	US LLC	Estonian OÜ	UAE free-zone company
Monthly, as triggered	—	TSD Annex 7 and INF 1 by the 10th after a dividend is paid	—
April 15	Form 5472 + pro forma 1120 due, or Form 7004 filed	—	—
June 30	—	Annual report due at the e-Business Register	—
September 30	—	—	Corporate tax return and payment due (nine months after year-end)
October 15	Extended Form 5472 due, if Form 7004 was filed in time	—	—
Set by the state or free zone	State annual report or tax — varies, check your state	—	Licence renewal — varies, check your free-zone authority

The cycles do not overlap: more than one entity means separate calendars, separate records and usually more than one professional.

Does owning two of these entities change the US filing?

Yes, if they transact with each other. If your OÜ or UAE company invoices the US LLC, pays its costs or receives money from it, that company is a foreign related party of the LLC and those transactions are reportable on the LLC's Form 5472, just like your own.

If the OÜ or UAE company is the LLC's direct owner, it becomes the direct 25% foreign shareholder, you are shown as the ultimate owner, and its FTIN is the company's own foreign tax or registry number, not yours.

Nothing merges. An Estonian annual report or a UAE corporate tax return does not satisfy the IRS, and a Form 5472 satisfies neither Estonia nor the UAE.

How do you file the US side?

Gather the year's records. List every transfer between you and the LLC, and between the LLC and any other entity you own, in US dollars.
Prepare the package. Complete Form 5472 and the pro forma Form 1120 with "Foreign-owned U.S. DE" at the top, including your FTIN or reference ID.
Sign it. The package is signed by the responsible person for the LLC.
Send it to the IRS. Fax to 855-887-7737 or mail to Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201. It cannot be e-filed.
Keep the evidence. Keep the fax confirmation or mailing proof. A fax receipt is transmission evidence, not IRS acceptance of the return.

Getting the US filing done

We prepare the US half — Form 5472 and the pro forma Form 1120 — and fax it to the IRS. Standard is $149 (5–7 business days), Express is $199 (within 3 business days), each additional past tax year is +$99, and IRS fax delivery is included. A qualified tax accountant reviews each package before it goes out.

We are not a CPA firm and do not give tax advice. We do not prepare Estonian, UAE or free-zone filings; those belong with a local accountant.

Frequently asked questions

Does an Estonian OÜ file Form 5472?

Not for itself. Form 5472 is filed by the US LLC. If your OÜ transacts with your US LLC or owns it, the OÜ appears on the LLC's Form 5472 as a related party, but the OÜ's own annual report goes to the Estonian business register.

Does a UAE free-zone company with a 0% rate still file a return?

Yes. The UAE Ministry of Finance states that all taxable persons, including free-zone entities, must register for corporate tax and file a return within nine months of the tax period's end. A Qualifying Free Zone Person must also keep audited financial statements.

When is the Estonian annual report due?

Within six months of the end of the financial year, according to RIK — 30 June for a calendar-year company. It is due even if the company had no economic activity.

Is the US LLC filing lighter than the other two?

It is different, not necessarily lighter. The federal filing is one information return a year, but it carries a $25,000 penalty exposure, cannot be e-filed, and sits alongside state requirements that vary by state.

Do I need an audit for my OÜ or UAE company?

For an OÜ, only above Estonian statutory thresholds — check with RIK or your accountant. For a UAE company, Ministerial Decision No. 84 of 2025 requires audited statements for Qualifying Free Zone Persons and for taxable persons with revenue above AED 50,000,000.

Does e-Residency or UAE residence remove the Form 5472 requirement?

No. Form 5472 depends on the US LLC being foreign-owned and having a reportable transaction. Neither e-Residency nor UAE residence changes that, and neither Estonia nor the UAE issues anything that replaces the US filing.

The three entities run on three separate calendars, and only the US one ends in an IRS fax. If your LLC's Form 5472 is due, start your filing here — and if you live in the UAE, read our UAE and Dubai residents guide first.

Moving between countries with this LLC? The Form 5472 guide for digital nomads covers filing when you have no single tax residence.

Educational content only; not tax or legal advice.