I don't want to be rude. But unless you are an accountant or really looked into this. You don't know what you are talking about. There are a lot of UKers on HN and a many are looking at Stripe Atlas. Things like this will undoubtably freak them out.
You are insinuating that HMRC views those setting up companies outside of the UK in order to avoid tax. This is not the case.
I've spoken to some US investors and the general consensus is that having a UK company is not seen in a positive light. It is preferable to have either an LLC or C-Corp.
Further more. From the article [1]: "HMRC argued that the profits taxed in the US were the profits of the LLC, whereas the profits taxed in the UK were the distributions made by the LLC to its member."
With respect to profits of the LLC: The first part is very important. HMRC themselves are stating that if profits of the LLC are repeatedly put back into the company and NO distributions to UK residents are committed. There is no tax liability.
With respect to profits on the dilutions [1]: "The Court concluded that the profit by reference to which Anson’s UK tax liability was computed was the profit arising as a result of the business being carried on by the LLC – this was undeniably the same profit on which Anson was taxed in the US and therefore double tax relief should be available."
So now there is NO question on any tax avoidance.
Finally, HMRC does have rules[2] which may affect Stripe UKers for as long as they reside in the UK.
I do strongly urge anyone reading this to confirm my research with an accountant, which I will be doing myself.
But please, do not believe random posts on HN!
[1]: http://www.williamfry.com/newsandinsights/news-article/2016/...
[2]: https://www.gov.uk/government/publications/issue-briefing-ta...
So you can certainly open an LLC from the UK but you'll be liable for UK Corporation Tax so I'm not 100% wrong.
I should clarify my previous statement. You can, of course, incorporate anywhere you like from the UK but HMRC will just ignore the fact you have incorporated abroad and tax you as if you were a UK corporation.