Case: Relocation of an IT Company from Estonia to the US. LLC Registration, CFC, GDPR Document Package, and Legal Business Support

The owner of an IT company specialising in proxy services and network solutions for businesses approached KRYNO. The company was registered in Estonia and worked with clients from the European Union, the United States, and other countries.

As the business developed, the owner made a strategic decision to relocate the company to the United States by registering a new legal entity in Wyoming. The main goal was to create a corporate structure better suited to further business scaling, the specifics of the proxy industry, and the requirements of international partners.

At the same time, the relocation required comprehensive legal support. It was necessary to properly wind down the Estonian company, fulfil CFC obligations in Ukraine, ensure a seamless transfer of operations to the new US company, and prepare a legal document package for the website in line with US jurisdictional requirements and GDPR.

What the project support included

Business structure analysis and relocation planning

At the first stage, the KRYNO team conducted a comprehensive analysis of the existing corporate structure, the company’s operating model, and the reasons for relocating the business to the United States.

We assessed the specifics of the proxy provider’s activities, the tax implications of changing jurisdiction, interaction with international partners, and prepared a step-by-step relocation plan that allowed all legal procedures to be completed without interrupting operations.

During preparation, we:

• analysed the corporate structure of the Estonian company;
• determined the procedure for terminating the activities of the previous legal entity;
• planned the registration of a new LLC in Wyoming;
• prepared a process for transferring agreements with partners and suppliers;
• synchronised the relocation process with compliance with Ukrainian CFC requirements.

As a result, the client received a clear transition plan that made it possible to complete all stages of the relocation without disrupting business continuity. The full transfer to the new jurisdiction, including transferring contracts to the new legal entity, took approximately three months.

Compliance with CFC requirements in Ukraine

Since the company owner is a tax resident of Ukraine, compliance with controlled foreign company requirements became a separate workstream.

KRYNO specialists analysed the ownership structure and prepared the documents required to properly terminate the client’s participation in the Estonian company.

As part of the support, we:

• prepared and filed the CFC notification;
• ensured preparation of the required CFC reporting;
• properly reflected the termination of participation in the Estonian company in connection with the business relocation;
• minimised tax risks and ensured compliance with Ukrainian law.

Thanks to the comprehensive support, the client fulfilled all tax obligations in Ukraine without having to deal directly with public authorities or navigate the specifics of international tax law.

Registration of a Wyoming LLC and transfer of operations

After the preparatory stage was completed, the KRYNO team organised the registration of a new US company — an LLC in Wyoming.

When building the new corporate structure, it was important not only to register the legal entity but also to ensure a seamless transfer of all operating activities without affecting the company’s work, clients, or partners.

As part of this stage, we:

• supported the registration of the Wyoming LLC;
• prepared the new company’s corporate documents;
• organised the transfer of existing agreements with suppliers and partners;
• synchronised the transfer of operations to the new legal entity;
• provided legal support for the change in corporate structure.

Thanks to detailed planning, the company continued operating as usual, and the relocation took place without interruptions in service delivery or performance of contractual obligations.

Preparation of the legal document package for the website

One of the key workstreams of this project was developing a complete legal document package for the company’s website.

Because the business operates in the proxy and VPN services sector, standard template documents were not sufficient. KRYNO lawyers prepared a set of documents tailored to the company’s activities, its new jurisdiction of registration, and international practices for digital services.

The document package included:

• Terms of Use (User Agreement) — rules for using the service that take into account the specifics of proxy and VPN services;
• Acceptable Use Policy (AUP) — a policy defining permitted use of the service and clearly specifying prohibited use cases;
• Privacy Policy;
• Cookie Policy;
• Data Processing Agreement (DPA) — for work with both clients and infrastructure providers;
• Refund Policy;
• KYC Policy for service users.

We paid particular attention to ensuring that the documentation would remain up to date not only at launch but also as the company continued to develop.

The package was built on a modular basis, making it possible to quickly adapt documents for new product launches, entry into new markets, or changes in the business model.

After the relocation was completed, the company expanded its product line by launching a VPN service. To support this legally, the KRYNO team prepared separate updates to the documentation. Overall, the legal document package was updated three times during the year in line with business development and new requirements.

Bringing operations into compliance with GDPR

Since a significant share of the service’s users are located in European Union countries, ensuring GDPR compliance became a separate workstream.

The KRYNO team analysed all personal data processing activities and adapted the internal documentation to European data protection requirements.

As part of this stage, we:

• analysed the processes for collecting and processing personal data;
• determined the legal bases for processing information;
• updated the Privacy Policy in accordance with GDPR requirements;
• prepared a Data Processing Agreement for interaction with clients and suppliers;
• regulated the procedure for exercising data subjects’ rights, including the rights of access, erasure, and data portability;
• defined the procedure for working with infrastructure providers acting as personal data processors.

As a result, the company received a legal framework for lawfully working with users in EU countries and for further scaling its international business in compliance with European legislation.

Ongoing legal support

After the relocation was completed, cooperation with the client transitioned to an ongoing legal support model.

The KRYNO team provides comprehensive support for the company’s development, ensuring timely updates to legal documentation, contractual support, and advisory assistance as the business grows and enters new markets.

As part of the ongoing support, we:

• conduct regular legal audits of the company’s activities;
• review and prepare agreements with partners, suppliers, and clients;
• update the legal document package in line with new product launches and legislative changes;
• advise on international corporate and tax law;
• support new legal matters arising as the business develops;
• train the client’s team on implementing legal requirements in day-to-day operations.

This cooperation model makes it possible to respond quickly to changes in the company’s activities and maintain legal compliance without having to engage new advisers each time.