Transfer Pricing for Small Structures: What Freelancers in Paraguay Need to Know in 2026

Transfer pricing is generally associated with multinational corporations: Apple invoicing its patents from Ireland, Google routing its revenues through the Netherlands, Amazon centralizing its profits in Luxembourg. But in 2026, transfer pricing rules will no longer concern only giants—they can also impact freelancers, consultants, and small entrepreneurs who use a US LLC from Paraguay. Why? Because from the moment you have two related entities in two countries (you in Paraguay + your US LLC in the United States), tax authorities can ask the fateful question: “Does the price charged between these two entities correspond to the market price?”

This guide demystifies transfer pricing for small entities in 2026: what it is, why tax authorities are interested, how it applies to your US LLC + Paraguay residency, what the real risks are (spoiler: low but not zero), and how to protect yourself without spending a fortune on Big Four consultants.

Transfer Pricing: The Concept in 5 Minutes

The Simple Definition

Transfer prices are the prices charged in transactions between related entities (i.e., companies that belong to the same group or are controlled by the same person). When one company sells a product or service to another company within the same group, the price of this transaction is a "transfer price."

Examples of transactions between related entities:

• The French subsidiary of an American group buys components from the US parent company → the price of these components is a transfer price.
• A Luxembourg holding company invoices "management fees" to its French subsidiary → the amount invoiced is a transfer price.
• A Paraguayan freelancer (you) provides consulting services through their US LLC, which invoices clients → the relationship between you (the actual service provider) and the US LLC (the invoicing entity) implies an implicit transfer price.

The Problem Transfer Pricing Creates

When two related entities are in countries with different tax rates, it is tempting to manipulate transfer prices to shift profits to the low-tax country:

• The French subsidiary (25% corporate tax) sells a service to the Irish parent company (15% corporate tax) at an artificially low price → profits end up in Ireland instead of France → less total tax for the group.
• Conversely: the Irish parent company charges high "royalties" to the French subsidiary → profits are transferred from a 25% country to a 15% country.
• This is exactly what the GAFAM companies did with the "Double Irish with a Dutch Sandwich" — and this is what transfer pricing rules seek to prevent.

The Arm's Length Principle

The fundamental rule of transfer pricing is the arm's length principle — Article 9 of the OECD Model Tax Convention and Article 57 of the French General Tax Code (CGI): transactions between related entities must be conducted under the same conditions (same price, same terms) as if the entities were independent of each other.

In other words: if your US LLC invoices a client 10,000 USD for a consulting service, this invoicing must correspond to what an independent provider would charge for the same service under the same conditions. If the price is artificially inflated or reduced to shift profits from one country to another, it is a manipulation of transfer pricing — and the tax authorities can issue an adjustment.

Transfer Pricing and Multinationals: The World of the Big Four

The Stakes for Large Companies

For multinationals (revenue > €750M), transfer pricing is a massive issue:

• Volume: 60-70% of global trade is intra-group (between subsidiaries of the same group). Transfer prices determine the distribution of hundreds of billions of euros in profits between countries.
• Mandatory documentation: groups with revenue > €400M (French threshold) must produce detailed transfer pricing documentation (Master File + Local File + Country-by-Country Report — CbCR). This documentation justifies the group's pricing policy and demonstrates compliance with the arm's length principle.
• Audits and disputes: transfer pricing audits are the main source of international tax disputes. Disputes involve billions (Apple: €13 billion adjustment in Ireland; Amazon: €250 million dispute in Luxembourg; Google: disputes in France, Italy, UK).
• Army of consultants: multinationals employ teams of 5-50 people dedicated to transfer pricing and spend millions in Big Four fees (Deloitte, PwC, EY, KPMG) to document and defend their policies.

Why it's disproportionate for a freelancer

You see the irony: the transfer pricing system was designed for the Apples and Googles of this world — not for an UX consultant invoicing €150,000/year via a US LLC from Asunción. But the law makes no distinction based on size: the arm's length principle applies to all transactions between related entities, regardless of size.

The good news: documentation obligations, intensive audits, and billion-euro disputes only concern large companies. A freelancer with a US LLC has no obligation for a Master File, Local File, or CbCR. The risk of a transfer pricing audit on a US LLC invoicing €200,000/year is infinitely lower than on a group with €10 billion in revenue.

But "infinitely lower" does not mean "zero." Let's understand when and how transfer pricing can affect a small entity.

Your US LLC and Transfer Pricing: The Analysis

The Typical Structure

The classic setup for a French-speaking expatriate in Paraguay:

• You: natural person, Paraguayan tax resident, service provider (consulting, freelance, development, design, coaching).
• Your US LLC: American company (Wyoming, Delaware, New Mexico), single-member (you are the sole owner). The LLC invoices your international clients. Revenues arrive at Mercury Bank.
• The relationship: you provide the services → the US LLC invoices the clients → the clients pay the US LLC → you use the funds (distribution or expenses via Mercury).

Is there a "transaction between related entities"?

This is the key question. For transfer pricing rules to apply, there must be a transaction between two related entities. Let's analyze:

• A single-member US LLC is "disregarded" in the USA: the IRS does not recognize a single-member LLC as an entity separate from its owner. There is no "transaction" between you and the LLC — the LLC IS you (fiscally). No transfer pricing is possible between an entity and itself.
• French law sees things differently: for French tax authorities (if France disputes your residency and tries to tax you), the US LLC can be treated as a separate entity (foreign company). If the French tax authorities consider the LLC as opaque (not transparent), they can see a transaction between you (assumed French resident) and the US LLC (controlled foreign company) — and apply transfer pricing rules.
• Paraguayan law: the Paraguayan DNIT (tax authority) does not have developed doctrine on the qualification of US LLCs. In practice, the DNIT treats the US LLC's income as foreign-source income of the owner (de facto transparency) and does not seek to apply transfer pricing rules between the Paraguayan resident and their US LLC.

The only scenario where transfer pricing concerns you

Transfer pricing concerns you only in one scenario: if the French tax authorities dispute your Paraguayan residency and reclassify you as a French tax resident. In this case:

1. The tax authorities consider you a French tax resident.
2. The tax authorities view your US LLC as a foreign company (potentially "controlled" within the meaning of Article 123 bis — see our CFC rules guide).
3. The tax authorities examine the transactions between you and the US LLC: the LLC invoices clients, holds the funds, and distributes (or not) profits to you. The tax authorities may ask: "If the US LLC is a separate entity, are the services Mr. X renders properly remunerated by the LLC? Does the LLC retain profits that should be paid to Mr. X?"
4. Application of Article 57 of the CGI: if the tax authorities determine that the transfer price between you and the LLC does not comply with the arm's length principle, they can make an adjustment by adding the difference between the price charged and the arm's length price to your French taxable income.

In practice, this scenario is always combined with a residency reclassification + CFC rules. Transfer pricing is an additional layer of potential adjustment — not an autonomous risk. If the reclassification fails (because your PY residency is solid), transfer pricing also does not apply.

Article 57 of the CGI: The French Transfer Pricing Rule

The Text

Article 57 of the CGI is the French anti-profit transfer provision:

In essence: when a French company (or a French taxpayer) conducts transactions with a related foreign company (directly or indirectly) and these transactions result in an indirect transfer of profits abroad (inflated or deflated prices, granted advantages), the transferred profits are reintegrated into the French tax base.

Conditions for Application

• Relationship of dependence or control: between the French entity and the foreign entity. You control 100% of your US LLC → clear relationship of dependence.
• Transaction between the two entities: a service provision, a payment of management fees, an invoice, a loan, an asset transfer. For a freelance US LLC: the service relationship (you provide the service, the LLC invoices the client).
• Undue advantage: the price of the transaction does not correspond to the arm's length price. For example: you provide full-time consulting services to the US LLC but the LLC does not pay you any remuneration (it keeps all profits). The tax authorities would argue: an independent consultant working full-time for a company would be remunerated. The absence of remuneration = indirect transfer of profits.

Application to a Single-Member US LLC

For a single-member US LLC of an expatriate in Paraguay, the application of Article 57 is legally complex:

• Tax authorities' argument: "The US LLC keeps the profits without properly remunerating you. If you were independent, you would charge a market rate for your services. The difference between your actual remuneration (€0 if you don't pay yourself a salary) and the market rate is an indirect transfer of profits to the US LLC."
• Counter-argument: "The US LLC is fiscally transparent in the USA. It has no independent tax existence. Its revenues are directly mine. There is no 'transfer' of profits since there is no separation between me and the LLC. It's as if I were invoicing under my own name — the LLC is just a legal vehicle, not a separate taxpayer."
• The legal debate: the qualification of the US LLC (opaque vs. transparent) under French law is not a definitively settled issue. The French tax authorities tend to qualify the US LLC as opaque when it suits them (to apply Article 123 bis or Article 57) and as transparent when it also suits them (to directly tax income as BNC). This lack of consistency is a legal uncertainty zone.

The Real Risk for a Freelancer in Paraguay: Pragmatic Analysis

Why the Risk is Low

1. The tax authorities must first reclassify you as a French resident: Article 57 applies only to French taxpayers (residents or French companies). If you are a Paraguayan resident, Article 57 does not concern you. The transfer pricing risk is conditional on residency reclassification — and this reclassification is itself a risk that your PY evidence file must prevent.
2. Small entities are not a priority: the French tax authorities focus their transfer pricing audits on large companies (stakes of millions/billions). A freelancer earning €200,000/year with a US LLC is not a profitable case for the tax authorities — the cost of the audit often exceeds the potential adjustment.
3. The single-member US LLC is an atypical case: transfer pricing rules are designed for intra-group transactions between separate entities (subsidiary A sells to subsidiary B). The transparent single-member US LLC does not fit this model — it is the owner themselves. Inspectors are less comfortable with this atypical case and prefer to use other tools (Article 123 bis, Article 4B) for adjustment.
4. No mandatory documentation: transfer pricing documentation obligations (Master File, Local File, CbCR) apply only to companies that exceed certain revenue thresholds (€400M in France for the Local File, €750M for the CbCR). A US LLC earning €200,000/year has no formal transfer pricing documentation obligations.

Why the Risk is Not Zero

1. The tax authorities use all available tools: in case of residency reclassification, the tax authorities stack the adjustment claims: Article 4B (residency) + Article 123 bis (CFC) + Article 57 (transfer pricing) + penalties. Each layer increases the amount of the adjustment. Even if transfer pricing is not the primary claim, it can be added to the others.
2. US LLCs without owner remuneration: if your US LLC invoices €200,000/year but does not pay you any formal remuneration (no salary, no documented management fees), the tax authorities can argue that the services you provide are not remunerated at market price = transfer of profits. This is a relatively simple argument for an inspector to build.
3. The hardening trend: BEPS Actions 8-10 strengthen transfer pricing rules and push for their application to small entities (not just multinationals). France is gradually transposing these recommendations. The control threshold could decrease over time.

The 5 OECD Transfer Pricing Methods

Why You Should Know Them

If one day the tax authorities question the transfer price between you and your US LLC, they will use one of the 5 OECD methods to determine the "arm's length price." Knowing these methods helps you understand the tax authorities' argumentation — and counter it.

Method	Principle	Application to a Freelance US LLC
1. Comparable Uncontrolled Price (CUP)	Compare the price of the controlled transaction with the price of a comparable transaction between independent parties.	What is the market rate for an independent UX consultant/developer/coach in the USA? If your LLC invoices 150 USD/h and the market rate is 100-200 USD/h, the price is arm's length.
2. Resale Price Method	Start from the resale price to the end customer and deduct an appropriate distribution margin. Less relevant for services (more for product distribution).	Less applicable to freelancers (no product resale).
3. Cost Plus Method	Start from the service provider's costs and add an appropriate profit margin.	Your cost (your "implicit salary" + charges + overhead) + a margin = the price the LLC should invoice. If the LLC keeps 100% of the profit without remunerating you, the cost plus method shows a transfer.
4. Transactional Net Margin Method (TNMM)	Compare the net margin of the controlled transaction with the net margin of comparable transactions between independent parties.	If independent consultants in your field have a net margin of 30-50% of their revenue, your LLC should have a similar margin — not 100% (which would imply you are working for free).
5. Profit Split Method	Allocate combined profits between related entities proportionally to their respective contributions.	You provide the work (100% of the value created). The LLC provides the legal structure and bank access (marginal contribution). Result: 95-100% of the profits should go to you. This is the case for a transparent single-member LLC.

The Most Relevant Method for a Freelancer

For a freelance US LLC, the most relevant method is the CUP (Comparable Uncontrolled Price) or the TNMM (net margin):

• CUP: Your US LLC charges the same rate an independent freelancer would for the same service. If your rate is within market range (verifiable on platforms like Upwork, Toptal, Glassdoor), the price is arm's length. No transfer.
• TNMM: Your net margin (profit / revenue) is comparable to that of an independent freelancer in your sector. If UX freelancers have a net margin of 40-60% and your LLC has a 50% margin, it is compliant. If your LLC has a 100% margin (because you don't pay yourself any remuneration and keep everything in the LLC), it is more debatable — but explained by the transparency of the LLC (profits are your income, not "retained" profits).

The specific case of the Paraguayan SRL

SRL + US LLC: two related entities in two countries

Some expatriates in Paraguay have two entities: a US LLC (for international clients) AND a Paraguayan SRL (for local clients or real estate). If the two entities transact with each other (the US LLC pays the PY SRL for a service, or vice versa), this is a transaction between related entities = transfer pricing applies.

• Example: Your PY SRL manages your rental apartments in Paraguay. Your US LLC invoices your consulting clients. The US LLC "lends" 50,000 USD to the PY SRL to buy an apartment. Is the loan at a market rate? If the rate is 0% (interest-free loan between related entities), an aggressive tax authority could argue that a loan between independent parties would be at 5-8% → indirect transfer of profits (the US LLC waives interest that should have been charged).
• Actual risk: Paraguay does not have a sophisticated transfer pricing control infrastructure. The DNIT will probably not challenge an intra-group loan of 50,000 USD. But if France reclassifies you as a French resident, it could analyze the US LLC ↔ PY SRL transactions and challenge the prices.
• Protection: Document transactions between your entities. If the US LLC lends to the PY SRL, create a loan agreement with a market interest rate (5-8% in USD). If the PY SRL provides a service to the US LLC, invoice at the local market rate. Transactions between related entities must be "arm's length" — even if both entities belong to you.

Paraguay and transfer pricing

Paraguay has introduced transfer pricing rules in its tax law (articles of Law 6380/2019 and DNIT resolutions):

• Scope: Paraguayan taxpayers who carry out transactions with foreign related entities (or in low-tax jurisdictions) must comply with the arm's length principle.
• Documentation: Documentation requirements are less strict than in France. No formal Master File/Local File for small businesses. However, taxpayers must be able to justify the prices charged in case of an audit.
• Practical application: The DNIT is in the process of building capacity in transfer pricing. Audits are rare for small structures. But the trend is towards strengthening — in line with OECD BEPS recommendations (Paraguay is a member of the Inclusive Framework).
• Impact for an expatriate: If your PY SRL buys services from your US LLC (or vice versa), the DNIT could theoretically request justification of the price. In practice: the risk is very low for small transactions. But keep basic documentation (contracts, price justification, market comparables).

Transfer pricing and service providers: specificities

The particularity of services vs. products

Transfer pricing rules were historically designed for product transactions (sale of components between subsidiaries, invoicing of patents). Their application to services is more recent and more nuanced:

• Intra-group services: When one entity provides a service to a related entity (management fees, IT services, internal consulting), the question is: does the service have real value for the beneficiary? And is the price compliant with the market?
• "Low value-adding" services: The OECD allows a simplified approach for "low value-adding" services (accounting, HR, IT support, administration): cost + 5% margin. If your US LLC provides administrative services to your PY SRL, the cost + 5% method is acceptable.
• "High value-adding" services: For consulting, strategy, technology development services — the added value is high, and the price must be justified by market comparables (not just cost + 5%).

The case of the freelancer who IS the service

In a freelance US LLC, you ARE the service. The LLC does not provide an "intra-group" service — it is the vehicle through which YOU provide a service to the end client. This distinction is important:

• Transaction 1 (LLC → client): The LLC invoices the client. The price is determined by the market (commercial negotiation between the LLC and the client = arm's length transaction by definition, because the client is an independent third party). No transfer pricing issue here.
• Transaction 2 (you → LLC): You provide the service, and the LLC "captures" the income. If the LLC is transparent (disregarded entity in the USA), there is no transaction — your income and the LLC's income are the same. No transfer pricing.
• The problem arises only if the tax authorities treat the LLC as opaque: In this case, the tax authorities see a transaction between you (provider) and the LLC (company). How much does the LLC pay you for your services? If the answer is "nothing" (you don't pay yourself a salary), the tax authorities can argue an indirect transfer of profits.

How to protect yourself: the practical strategy

Strategy 1: Regularly distribute profits

The simplest protection against transfer pricing risk (and CFC risk) is to distribute 100% of the US LLC's profits each year. If the LLC retains no profits (everything is distributed to the owner), there is no "transfer" of profits to the LLC — the profits return entirely to you.

• How: Each month or quarter, transfer profits from Mercury Bank to your personal Paraguayan account or to Interactive Brokers. The LLC serves as a conduit — not a reservoir.
• Documentation: Mercury → personal account transfers are "member's distributions." Note them in your LLC records (operating agreement, register of distributions).
• Result: As of December 31, the LLC has a minimal balance (just the cash needed for current operations). No retained profit = no transfer = no transfer pricing.

Strategy 2: Document the market price of your services

Even if you have no formal transfer pricing documentation obligation, having a basic file is valuable protection in case of an audit:

• Informal benchmark: Compile some data on market rates for your type of service (UX consulting, web development, coaching, etc.). Sources: Glassdoor, Upwork, Toptal, PayScale, industry reports.
• Your rate vs. the market: If you charge 100-200 USD/h and the market is 80-250 USD/h for similar skills, you are within range. Document this comparison (screenshots of platforms, report excerpts).
• Cost: 0 € (public data) to 500-1,000 € (if you ask an accountant to formalize the benchmark). No need for Big Four — a simple 2-3 page document is sufficient.

Strategy 3: Invoice your clients at market prices

If your rates are competitive and comparable to those of other providers in your field, there is no transfer pricing manipulation. The tax authorities cannot challenge a price that corresponds to the market — even if that price generates a high profit in a low-tax US LLC.

• The test: If an independent client is willing to pay that price for your service, it is an arm's length price. Your contracts with third-party clients (not related to you) are the best proof that your prices are market-based.
• The trap: If you invoice your sole French client (who is also your former employer) at a rate 3x higher than the market, the tax authorities can argue that the price is artificially inflated. Solution: invoice at the market rate and diversify your clients.

Strategy 4: Separate US LLC and PY SRL

If you have a US LLC AND a PY SRL, minimize transactions between the two:

• The US LLC invoices international clients. Revenues remain in the USD/Mercury system.
• The PY SRL invoices Paraguayan clients and manages local real estate. Revenues are in guaranis/USD in the PY account.
• No cross-invoicing (the LLC does not invoice the SRL, the SRL does not invoice the LLC) unless there is a real commercial need.
• If a transfer is necessary (the LLC lends to the SRL for a real estate investment), document it with a market-rate contract.

Strategy 5: Transparency as a shield

Transparency is the best defense against transfer pricing accusations:

• US LLC declarations to the IRS (Form 5472) up to date — they document the LLC's transactions.
• DNIT declarations in Paraguay up to date — they show your declared local income.
• Archived Mercury Bank statements — they show the LLC's cash flows (client revenue → member distributions → investments).
• LLC operating agreement documenting the distribution policy.

A tax authority that examines your file and sees: (1) a transparent LLC in the USA, (2) regular distributions to the owner, (3) market prices for your services, (4) up-to-date declarations in both countries, and (5) no artificially retained profit in the LLC — has no basis for a transfer pricing adjustment.

BEPS and transfer pricing: what changes for small structures

BEPS Actions 8-10: reinforced rules

BEPS Actions 8-10 have reinforced transfer pricing rules:

• Alignment with value creation: Profits must be attributed where value is created (where work is done, where decisions are made, where risks are managed). For a freelancer in Paraguay: value is created by YOU, in Paraguay. Profits return to you — this is consistent.
• Enhanced substance: Entities that receive profits must have proportional substance (personnel, assets, decisions). Your US LLC has no US personnel or US office — but it doesn't need to because it is transparent (you, in Paraguay, are the substance).
• Transfer of intangibles: BEPS rules strengthen control over transfers of intellectual property (patents, trademarks, software) between related entities. If you developed software personally and transfer it to your US LLC, the transfer price of that software must correspond to its market value. Relevant for developers and SaaS creators.

Action 13: Country-by-Country Reporting

BEPS Action 13 created Country-by-Country Reporting (CbCR) — but it only applies to groups with revenue > €750M. For small structures: no CbCR obligation. But thresholds could decrease in the coming years (discussions about a threshold of €250M or even €50M). Even with a threshold of €50M, your US LLC at €200,000 is not concerned.

The summary table: transfer pricing and small structures

Situation	Transfer pricing risk	Recommended action
Single-member US LLC, PY resident, no challenged FR residence	Almost zero (no FR residence = no application of art. 57)	Maintain solid PY residence. Distribute profits regularly.
Single-member US LLC, PY residence challenged by FR tax authorities	Moderate (tax authorities may add art. 57 to art. 4B + 123 bis adjustment grounds)	Impeccable PY residence file (to prevent reclassification). Informal market price benchmark. Regular profit distribution.
US LLC + PY SRL with cross-transactions	Low to moderate (DNIT could theoretically challenge intra-group prices)	Document LLC ↔ SRL transactions. Market-rate loan agreements. Comparable price invoicing. Minimize cross-transactions.
US LLC with a single French client (former employer)	High (FR tax authorities may argue that the activity is from FR source and the price is artificial)	Diversify clients (not 100% FR). Invoice at market rate. Conduct activity FROM Paraguay (not in France).
Transfer of intellectual property to US LLC	Moderate to high (if software/patent developed in France is transferred to US LLC without an arm's length price)	Value IP at market price. Document transfer. If IP is developed in Paraguay, the risk is lower (no transfer from France).

What your accountant needs to know

For the Paraguayan accountant

Your Paraguayan accountant (€30/month) needs to know that:

• Paraguayan transfer pricing rules exist (Law 6380/2019) but are rarely applied to small structures.
• If your PY SRL transacts with your US LLC, prices must be basically documented (contracts, rate justification).
• IRP and IRACIS declarations must accurately reflect your Paraguayan-source income — US LLC income (foreign source) is not declared in Paraguay (territoriality).

For the American CPA

Your American CPA (who manages the US LLC's Form 5472) needs to know that:

• Form 5472 declares the single-member LLC's transactions with its foreign owner. These transactions must be reported accurately (distributions, capital contributions, loans if applicable).
• The LLC has no formal transfer pricing documentation obligation in the USA (no Master File/Local File) — but transactions declared on Form 5472 must be consistent.

For the French tax lawyer

In the event of a French tax audit, your lawyer must be able to argue that:

• The US LLC is transparent in the USA (disregarded entity) → no "transaction" between separate entities → no transfer pricing applicable.
• Even if the LLC is treated as opaque, prices charged to clients are arm's length (market benchmark).
• Profits are regularly distributed (no profit retained in the LLC = no transfer).
• The LLC has commercial substance and logic (not a shell company created solely for tax purposes).

Conclusion

Transfer pricing is an international tax concept designed for multinationals — but which can theoretically affect small structures like a freelance US LLC. The principle is simple: transactions between related entities must be at market price (arm's length principle). The risk is complex: the French tax authorities can use Article 57 of the CGI to challenge prices between you and your US LLC — but only if they first manage to reclassify you as a French tax resident.

For a freelancer in Paraguay with a US LLC, the transfer pricing risk is low but not zero:

• Low: Because the tax authorities must first succeed in reclassifying residence (your solid PY file prevents this), because small structures are not a priority for transfer pricing audits, and because a transparent single-member LLC is an atypical case that does not fit the classic transfer pricing scheme.
• Not zero: Because the tax authorities stack adjustment grounds in case of reclassification, because the qualification of the LLC (opaque vs. transparent) is uncertain under French law, and because BEPS rules push for increased controls — even on small structures.

Protection is pragmatic: distribute profits regularly (no retained earnings in the LLC), invoice at market prices (maintain an informal benchmark), document your transactions (contracts, statements, declarations), and above all — secure your Paraguayan residency (residency is your first line of defense against ALL French tax risks, including transfer pricing).

Transfer pricing is a Big Four issue for multinationals. For a freelancer in Paraguay, it's a manageable marginal risk with common sense, basic documentation, and solid residency. Don't let the theoretical complexity of the subject paralyze you — the fundamentals remain the same: live in Paraguay, invoice at market price, distribute your profits, and document everything.

Do you want a transfer-pricing-proof US LLC structure? Contact our team for comprehensive support: Paraguayan residency (from €1,400), properly structured US LLC, DNIT accounting (€30/month), and coordination with your US CPA and tax lawyer. The simple structure is the safe structure — and the safe structure is the one that withstands all audits.