Private limited company
A private limited company is any type of business entity in "private" ownership used in many jurisdictions, in contrast to a publicly listed company, with some differences from country to country. Examples include: the LLC in the United States, private company limited by shares in the United Kingdom, GmbH in Germany and Austria, Besloten vennootschap in The Netherlands and Belgium, société à responsabilité limitée in France, società a responsabilità limitata in Italy, and sociedad de responsabilidad limitada in the Spanish-speaking world. The benefit of having a private limited company is that there is limited liability.
Abbreviations
Albania
In Albania, a limited liability company is a commercial company founded by persons of physical or judicial status, who are not liable for the company and personally bear losses only up to the outstanding contribution agreements. Partners' contributions constitute the registered capital of a limited liability company. Each partner has his quota in the company in proportion to the contribution of the capital so the registered capital of the company is divided between the partners based on the proportional ratio of their contribution. In Albania a limited liability company may not have a capital of less than 100 lek.Argentina
Although not an exact equivalent, the Argentine variant of the LLC is called Sociedad de Responsabilidad Limitada and it limits the liability of its members up to their capital contribution in the company. The equity is divided into equal stakes, each one of which represents a percentage of the company and that can not be traded on the stock exchange. Their by-laws are regulated by law N° 19550 and the commercial partnership is limited to a maximum of 50 partners.Bolivia
In Bolivia, the LLC variant is called Sociedad de Responsabilidad Limitada. These companies' legal framework consist in the Trade Code, its modifications and other supplementary laws. The members participate in it through capital stakes, and their liability is limited to the value of their contributions. The number of members must be minimum 2 and maximum 25.Bosnia and Herzegovina
Bosnian and Herzegovinian legislation, similarly to that in Serbia, Montenegro, North Macedonia contemplates LLCs as društvo s ograničenom odgovornošću. Companies using this structure append the abbreviation d.o.o. to their company name. A shareholder or member in a d.o.o. is only personally liable up to the value of the member's investment in the company.Brazil
The corporate structure in Brazilian law most similar to the American LLC is the Sociedade Limitada, under the new Brazilian Civil Code of 2002. The sociedade limitada is the new name of the sociedade por quotas de responsabilidade limitada, and it can be organized as empresária or simples, under this new code, roughly corresponding to the form types of comercial and civil of the Commercial Code. A new law in Brazil has made it legal to obtain an LLC by a sole-proprietor in two forms: Empresa Individual de Responsabilidade Limitada, or Sociedade Unipessoal Limitada. The main requirement for an Eireli is a capital of 100 times the current minimum wage, R$ 78.800,00 as of 2015; whereas for a Sociedade Unipessoal Limitada the same rules apply as for other ''Sociedades Limitadas''Bulgaria
Bulgarian legislation corresponds LLCs as "Дружество с ограничена отговорност". Companies incorporated under this structure append the cyrillic abbreviation ООД to their name. In the case of an LLC incorporated with a sole-shareholder/member, this is designated and known as "Еднолично дружество с ограничена отговорност" and abbreviated as ЕООД. The EOOD specifically, is exempted from annual, general or extraordinary meetings for making decisions and may just issue written resolutions.As part of the European Union Bulgarian companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Colombia
Colombian legislation contemplates a very similar structure as mentioned above in the Chilean case. The Ltda. abbreviation is also used in Colombia.Croatia
In Croatia, a private limited liability company is termed društvo s ograničenom odgovornošću, abbreviated d.o.o.. A public limited liability company is termed a dioničko društvo abbreviated d.d..As part of the European Union Croatian companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Czechia
Czech legislation contemplates LLCs as společnost s ručením omezeným. An s.r.o. is not technically comparable to an LLC because the profits are still subject to double taxation. Czech law does not offer a possibility to start up a limited company without the possibility of avoiding double taxation. As of 2014 the liability is not limited in Czech, since managing director bears full liability that extends to all of his/her property, including private one.As part of the European Union Czech companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Denmark
The Danish form of the LLC is the kommanditselskab. There is no minimum capital requirements. In a K/S there are two types of shareholders, the komplementar which is fully liable, and the kommanditist which liability is limited. The K/S is a tax-transparent company, which means the income "passes through" the company directly to the shareholders.As part of the European Union Danish companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Dominican Republic
Dominican Republic legislation contemplates LLCs as Sociedad de Responsabilidad Limitada, also known by their abbreviation S.R.L. S.R.L.s award limited liability to their members up to their contribution in the company. This type of company began after the law number 479 of the year 2008.Estonia
The Estonian version of private limited company is called osaühing. The type of entity is also required to be identified in the name.An OÜ is taxed as a corporation. The minimum capital required by law is as low as €0.01 per shareholder.
As part of the European Union Estonian companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Finland
Although not an exact equivalent, the Finnish version of the LLC is the Oy or in Swedish Ab. An Oy is taxed as a corporation. Since 1 July 2019, there is no minimum capital required by law.As part of the European Union Finnish companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Germany
Because of its hybrid characteristics it is very difficult to determine the German equivalent. On one hand it is possible to consider it as a kind of Gesellschaft mit beschränkter Haftung because it has aspects of a corporation; on the other hand it could be considered to be a kind of Kommanditgesellschaft, which is the German equivalent of a limited partnership. Based on the literal translation of the word "company", an LLC should be considered to be a kind of KG without any liable partner. The German equivalent that comes closest to LLC, is GmbH & Co KG, a nested Kommanditgesellschaft where a Gesellschaft mit beschränkter Haftung takes the role of the fully liable partner. For the purpose of taxation, the Bundesfinanzministerium gives detailed guidelines of the circumstances under which an LLC is to be considered to be a "corporation" or as a "limited partnership". It is useful to note, however, that the original LLC statutes of Wyoming and other US states were more or less explicitly modeled after the GmbH.As part of the European Union German companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Greece
A limited liability company in Greece is synonymous to an EPE.As part of the European Union Greek companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.
Hong Kong
In Hong Kong, the Limited Company is the most commonly incorporated type of company and bears the characteristics of a Limited Liability Company. The core characteristics of a Hong Kong Limited Company include: i) it requires a minimum of one shareholder and one director a Hong Kong company requires a company secretary resident in HK, iii) foreign ownership is allowed, iv) company shareholders have limited liability and v) the company must have registered HK address.Entrepreneurs who register a company in Hong Kong can choose a Hong Kong offshore company. This company structure is basically a HK Limited Company but all business is conducted outside of Hong Kong. The advantage of this structure is that all business income that is sourced outside of Hong Kong is tax exempt.
Hungary
Hungarian legislation contemplates LLCs as korlátolt felelősségű társaság. Companies working under this structure append the abbreviation Kft. to their name. Hungarian LLCs are required to have a 3 million HUF starting capital. The time of formation by the new electronic formation option has been reduced from 2 weeks to 2 hours, additional cost of formation is around 100,000 HUF. Kft.s can be formed by the cooperation of lawyers.The Hungarian kft. is the most common form of doing business in Hungary.
As part of the European Union Hungarian companies can obtain an EU VAT registration number for cross-border trade within the EU, can be searched by both VIES and BRIS.