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In which EU countries can companies elect pass-through taxation or at least there exists a company form with pass-through taxation?

Personal Finance & Money Asked by Pawel Debski on March 29, 2021

I am looking within EU for a tax solution similar to S Corporations in the US:

An S corporation, for United States federal income tax, is a closely held corporation (or, in some cases, a limited liability company (LLC) or a partnership) that makes a valid election to be taxed under Subchapter S of Chapter 1 of the Internal Revenue Code. In general, S corporations do not pay any income taxes. Instead, the corporation’s income and losses are divided among and passed through to its shareholders. The shareholders must then report the income or loss on their own individual income tax returns.

One Answer

Here are my findings to date:

  • The Netherlands (Closed Partnership - CV - beware changes as of Jan. 2022)
  • Estonia general partnership - TÜ - and limited partnership - UÜ - are only tax-transparent when in special "shared investment" regime (beware however possible ATAD2 legal changes as of Jan. 2022)
  • Poland (partnership - Spolka Jawna / Partnerska - and limited partnership - Spolka Komandytowa - beware legal changes announced for Jan. 2021!)
  • Switzerland KG and KGaA also have single taxation and even if CH is not part of EU it is part of EFTA which make many things easier than with US-based S-Corp

As far as I know other Baltic States now popular among startups do not offer this favourable tax regime.

Additional info from other posters highly welcome.

Correct answer by Pawel Debski on March 29, 2021

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