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2•toomuchtodo•1h ago•1 comments
Open in hackernews

SourceHut moves business operations from US to Europe

https://lists.sr.ht/~sircmpwn/sr.ht-dev/patches/60282
189•DyslexicAtheist•7mo ago

Comments

wyldfire•7mo ago
The relevant portion of this change is the addition of "European" in "You must obey all local, US, European and Dutch laws ...", I guess?

Not super clear from the link that's the case. Maybe sourcehut will make an explicit publication to this effect.

diggan•7mo ago
> relevant portion of this change is the addition

No, that was there before too. What's new is the legal address in the bottom, that now specifies Netherlands, and a KVK+BTW identifier.

"-" prefix on a line in a diff indicates removals, "+" prefix indicates additions.

But yeah, I'd expect them to also make some sort of announcement blog post explaining the change.

3D30497420•7mo ago
This has been awhile in coming. They incorporated in the Netherlands a few years ago: https://sourcehut.org/blog/2022-10-31-tos-update-cryptocurre...
bgwalter•7mo ago
The Netherlands is one of the most surveilled societies on earth. This is from 2016 and it has only gotten worse:

https://www.irishtimes.com/news/world/europe/sweeping-survei...

f_devd•7mo ago
This seems demonstrably false, e.g. GFW of China, and similar cases of effectively the entire country being under surveillance: https://www.statista.com/statistics/1290708/top-surveilled-c...
thedevilslawyer•7mo ago
I mean if you have to give that as the only example, then GP's point stands very strong.
f_devd•7mo ago
It's really not worth my time finding the research for every single fallacious claim made; the Netherlands is not in the top 10 for physical or digital surveillance[0], nor is it likely get close to China or USA even if they wanted[1]

[0]: https://www.tooltester.com/en/blog/the-worlds-most-surveille... [1]: https://www.forbes.com/sites/emmawoollacott/2020/10/06/eu-co...

bgwalter•7mo ago
The Netherlands essentially has pre-crime units:

https://www.theguardian.com/cities/2018/mar/01/smart-cities-...

The city also keeps track of the number of young people hanging out in the streets, their age group, whether they know each other, the atmosphere and whether or not they cause a nuisance. Special enforcement officers keep track of this information through mobile devices. It calls this process “targeted and innovative supervision”. Other council documents mention the prediction of school drop-outs, the prediction of poverty and the monitoring of “the health of certain groups” with the aim of “intervening faster”.

f_devd•7mo ago
Except it's not actually being used anymore [0] with the original operations, scope and data all being documented publicly. That's the downside of referencing 7 year old articles.

[0]: https://algoritmes.overheid.nl/en/algoritme/gm0344/78136377/...

amiga386•7mo ago
SourceHut isn't under Dutch law because it's the best legal jurisdiction to run a code hosting service from. It's because the sole trader who runs this particular code hosting service personally moved to the Netherlands, so that's the easiest place for him to run his business from.

Also, this diff does not say his business has left US jurisdiction:

- before: "You must obey all local, US, and Dutch laws"

- after: "You must obey all local, US, European, and Dutch laws and regulations"

diggan•7mo ago
> Also, this diff does not say his business has left US jurisdiction:

That is true, but the commit message also says:

> v2: rollback the premature removal of compliance with US law - Will defer this until we finish shutting down the US business entity entirely.

So it seems leaving US jurisdiction is planned, it was just a bit premature so they temporarily rolled that particular change back.

bee_rider•7mo ago
The country with the most surveillance laws in the books and the most documented phone taps is probably not the most surveilled country on earth (at least, for the worst countries I expect law enforcement to just do whatever they want and not leave a paper trial because… why would they bother? Nobody is going to scrutinize them anyway).

Of course, this puts the conversation in a tricky spot. The less-bad actors (no country is great in this context) should have the most well documented abuses, the worst will just do it without bookkeeping. So it is, unfortunately, a “prove a negative” sort of thing.

jeroenhd•7mo ago
I think the difference between the Netherlands and other countries is that the Netherlands is quite open about the amount of phone taps they place. You'd be crazy to think other countries don't tap phone lines at the same rate or worse.

As bad as the surveillance situation here is, it's still better than the situation in the UK, of that I'm sure. Unfortunately, I can't find any very recent data about wiretaps in the UK. The 2023 report (https://ipco-wpmedia-prod-s3.s3.eu-west-2.amazonaws.com/E032...) shows a sharp rise in communications data applications (441,900 in 2023 alone) but those can range from single phone calls to months of data collection. The Dutch reports only claim 5397+1258 phone taps in 2024, but those don't say anything about their daily volume.

If your government's wiretaps per capita is lower, double check that they're not using coded language to exclude most of their activities, and if the numbers are much lower, think twice before taking them for their word.

perching_aix•7mo ago
This is about drafted, pending changes to legislation. Did these changes actually go through, and do so unmodified?
bilekas•7mo ago
Does anyone know the context around this ? It's not clear form the PR at all. Was there some US regulation/requirement that SH didn't agree with ?
cess11•7mo ago
The political and regulatory climate in the US is quite volatile and has been for years, and perhaps they also disagree with the lack of data protection rights.

They have a bit of an ethical track record where they've disallowed use of their services for crypto commodity projects and the like, for example.

simianwords•7mo ago
This doesn’t track at all. I’m not an expert but from what I heard startups are moving away from Europe not the other way round. It does seem to be a political or lifestyle choice as a sibling comment pointed out.

Edit: I mean ideological not exactly political choice.

>I have felt a kind of dissonance with my home country of the United States for a long time now, and I have found it very difficult to resolve. I am not of one mind with my peers in this country on many issues; social, economic, and political. Even limiting this inquiry to matters related to FOSS, it’s quite clear that the FOSS community in Europe is much stronger than in America. In the United States, capitalism is the secular religion, and my values, in FOSS and otherwise, are incompatible with the American ethos.

Seems ideological to me.

simianwords•7mo ago
For people downvoting may I ask why? Isn’t it common knowledge that Netherlands is not the most favourable place to run a company?
bilekas•7mo ago
> I’m not an expert but from what I heard startups are moving away from Europe

Where are you getting that info from ? There's more invesment that ever in EU startups.

One I know of recently : https://www.eu-startups.com/2025/06/italian-publishing-house...

simianwords•7mo ago
So too in India. But you won’t see startups moving to India (unless for ideological reasons).

Simply proving that there are some startups is not useful. I still think it has to do with the founder’s personal ideology.

the-anarchist•7mo ago
Precisely because the average participant of this platform has as much in-depth experience in actually incorporating and running a company in different parts of the world as the average person on the street.

Netherlands, and the EU in general, are cumbersome to deal with regardless of all the "startup incentives" they've been pushing in the past few years. Compare the incorporation, maintenance and closure processes of a Delaware/Wyoming/New Mexico/Florida LLC with anything even remotely comparable in Europe (e.g. a BV/NV/SRL in the Netherlands) and you will quickly see why the US has become the world's center-stage for doing business.

For SourceHut Estonia and Romania would have probably been a better choices, as from my understanding, they are not investor-driven and do not seem to head that way, they are fully digital/remote, and they require disproportionally more infrastructure than office workers to operate.

However, when living in the EU one has to take into account various (frankly absurd) taxation laws that might ultimately prevent founders from incorporating their company in any of the neighboring countries. Hence it would be necessary to look at the details of the founder's circumstances to evaluate if incoporation in a different country would have made sense to begin with.

That said, I agree with the top rated comment [1] as for the broader topic of where to incorporate.

[1] https://news.ycombinator.com/item?id=44366032

simianwords•7mo ago
This is what I gathered too. Why then do you think he chose to move to Netherlands?
nemomarx•7mo ago
The benefits and practicality of living in a country are different than those of running a company in it, right? And he kept the company in the us for some time after the move from the sounds of it.
simianwords•7mo ago
Yes but moving to Netherlands was ideological. What follows is obviously practical.
the-anarchist•7mo ago
From the limited information that appears to be available I would assume that the reasons to move operations from the US to NL were largely personal. Reading through the other comments in this thread and some of the content on the founder's own website gives some clues.

My theory is that they are eyeing to get rid of their US citizenship and naturalize in the Netherlands, which is possible after 5 years when certain criteria is met. Having economic ties to the country you're trying to get citizenship in helps immensely. The logical next step for them would be to open a physical location and employ Dutch citizens to further solidify their case.

You have to remember: As long as the founder is still citizen of the United States, they will inevitably support the country and its policy with the taxes on their world income. After all, the US is one of only three countries in the world that taxes based on citizenship rather than residency.

Having that said, there have been various attempts across Europe to change from residency-based taxation to citizenship-based taxation in the past decades. All of which have been unsuccessful so far.

gbear605•7mo ago
> After all, the US is one of only three countries in the world that taxes based on citizenship rather than residency.

This is true, but only on taxable income over $130,000. Drew is probably not making over that from Sourcehut, so he’s not going to be paying any taxes to the US anyway.

jamil7•7mo ago
> For SourceHut Estonia and Romania would have probably been a better choices

Doesn't the ease of incorporation get erroded by the ongoing burden of filing taxes in multiple places? I remember looking at this years ago as an alternative to a GmbH and thinking it wasn't worth it. Maybe for this type of company it is.

the-anarchist•7mo ago
This depends on many details and there's no general answer to your question. Also, Estonia and Romania do not only offer easier incorporation, but are an overall better fit for businesses like the one presented here (at least from the limited information that I was able to gather on it) due a higher flexibility, more favorable taxes, and fewer regulations in general.

Since you're mentioning a GmbH I'm assuming you're based in either Switzerland, Germany or Austria. Generally speaking, regulation and tax codes in these countries have made it very unfavorable to operate any foreign entity, unless there's a fair amount of substance and structure in the target jurisdiction that make it worthwhile.

However, it is important to mention that while it is often the "natural" thing to do, operating a business in the same country that the founder is based in is almost never ideal from a regulatory and tax perspective. Unforunately, though, proper planning and execution of advanced structures is usually not something the average startup founder is a) primarily interested in and b) able to afford.

Given the other comments in this thread mentioning the founder's rather left-leaning political views, I assume that regulatory and, specifically, tax optimization were none of the founder's main goals to begin with.

nottorp•7mo ago
If you want VC money you have to be incorporated in Delaware, I think. If you don't, you get a choice.
the-anarchist•7mo ago
If you want US VC money, that is. If you are happy with cheques from big oil you might as well incorporate in the UAE. There are many places around the world that are friendly towards VC investments/startups (Singapore, Hong Kong, the aforementioned UAE, just to name some). However, sadly the EU is not one of them.
cess11•7mo ago
Kind of weird thing to lie about.

https://www.globalfounderscapital.com/

https://www.htgf.de/

https://seedcamp.com/

https://www.parequity.com/

https://partechpartners.com/

https://www.speedinvest.com/

https://www.kimaventures.com/

Then there are many niche VC-networks, like https://www.timetoraise.co/.

nottorp•7mo ago
Confusing the availability of non US funding with where the most money is, especially for the HN crowd…
Vinnl•7mo ago
The comment you're replying to pretty much describes it as a political choice? I don't see why that doesn't track at all.
simianwords•7mo ago
Sorry I meant ideological choice.
Vinnl•7mo ago
Well, that too? Wanting data protection rights, not wanting to potentially suddenly be subject to tariffs, etc. seems to fit that mould.
simianwords•7mo ago
How does it personally help his company?
Vinnl•7mo ago
I'm not sure I understand the question, since a company is not a person, but it helps the company to attract customers if they're subject to reputable data protection laws, and they can better plan for the future and retain more profit if they don't have to prepare for e.g. sudden tariffs that could be instituted on a whim?
bee_rider•7mo ago
Is this really a meaningful distinction? It is good to have your company in a place that is politically/ideologically compatible with yourself, and also your business model.
simianwords•7mo ago
Yes it is a meaningful distinction. If I move my company to Saudi Arabia because I am a Muslim wouldn’t that be an important detail?
bee_rider•7mo ago
Sorry, I think I was unclear. In your follow up post, you said, initially you said political choice, but actually now you mean ideological. Is there a meaningful distinction between political, and ideological, in this context?

Like if you moved to Saudi Arabia, and the motivating concern was ideological rather than political… I don’t know, what’s the difference? Is it a big picture vs little details thing?

I bet the reasons for the move were: ideological, political, lifestyle (maybe they have better weather and nicer cities)—moving countries is a big decision.

simianwords•7mo ago
Ok I was the one unclear. I meant it was ideological and not related to practical matters of running the company.

The difference between ideological and practical (not political) is crucial. Practical reasons can generalise to everyone but not ideological reason. I wouldn’t move to Saudi for example because I’m not a Muslim. But if I were to understand that he moved due to practical reasons that matter for his core business then that is generalisable.

bee_rider•7mo ago
I think the line is still a bit fuzzy in the case of a small single-proprietor (at least as far as I know, maybe he hired some more folks, I haven’t been keeping track) company like SourceHut. I mean, it is a company that has become well known around here because the owner made a lot of practical, nuts-and-bolts decisions aligned to his ideology (like the decision to price things from the start to make a reasonable little profit, an explicit rejection of the hypergrowth ideology).

> Practical reasons can generalise to everyone but not ideological reason. I wouldn’t move to Saudi for example because I’m not a Muslim. But if I were to understand that he moved due to practical reasons that matter for his core business then that is generalisable.

I think I sort of disagree that practical reasons are universally generalizable in a way that ideological reasons aren’t.

Practical reasons are generalizable in some cases, but your ability to learn practical lessons from somebody else will depend on how your situations are practically similar.

Ideological reasons are also generalizable in some sense—I mean, lots of people have similar ideological beliefs. And SourceHut was founded on ideological principles that are not universally held, but which are widespread enough for folks here to at least be curious about them here.

Barrin92•7mo ago
>but from what I heard startups are moving away from Europe

pretty much the other way around. Europe's startup base is still smaller than the US but has been growing faster. It's now 20% or so of global VC capital compared to about 5% a decade ago, and has produced unicorns at faster rates. Just misses the mega-sized companies at the tail end (https://tech.eu/2023/07/05/europes-best-decade-in-tech-reach...)

You can just look at an investor like, ironically enough, Thiel who has been pumping a lot of money into European tech. Defense startups in Germany for example.

simianwords•7mo ago
Also there is absolutely no proof of startups moving to Europe than other way round. You haven’t provided evidence or even anecdotes of it.

Merely showing some startups gaining funding doesn’t show the full picture - I can also show similar statistics from India but you don’t see companies moving to India.

throw-the-towel•7mo ago
Companies absolutely are moving many jobs to India.
msgodel•7mo ago
If they're going to do that anyway who cares if they're in your country? In fact it almost makes sense to have as few as possible there because they're just going to do lobbying for regulatory capture.
EasyMark•7mo ago
If the owner moved to Europe then it's likely either personal (marriage? family there?) or political/philosophical difference with the authoritarianism starting to effuse the USA, and not related to regulations, as they'll still have to abide by most or all US regulations to do business here.
simianwords•7mo ago
Agree. This is important to clarify because it helps others decide whether it is indeed useful for them to move operations to Europe.
delfinom•7mo ago
Start-ups maybe moving away from Europe but they won't be selling to European customers. The EU is increasingly moving to assert data sovereignty and control. The US abusing sanctions and tariffs have basically guaranteed it will become set in stone law, after years of it being a debate and exceptions being made.
throwaway2037•7mo ago
Sorry, I am dumb here. Honest question: In English, what is the difference between "ideological choice" and "political choice"? To me they seem similar, but I am sure that you used them with specifically different meanings.
skrebbel•7mo ago
You're just guessing what the context might be.
cess11•7mo ago
Yes, that's why I wrote "perhaps", and I based it on what I called their ethical track record. It stands to reason to assume that they might not want to stick around under a crypto scammer government like the current one, since they've kicked crypto commodity projects from their service.
mrweasel•7mo ago
Part of it seems to simply because the owner moved[1] and it makes sense to move his company with him. Given that Source Hut have physical hardware and operating that from across the ocean probably gets tiresome pretty fast it also makes to move the hardware. So now the owner, and the hardware is in Europe. At that point you kinda have to live be the local rules anyway and having your business being a US business makes little sense and provides no actual benefits.

1) https://drewdevault.com/2021/06/07/The-Netherlands.html

reisse•7mo ago
I'd wish there were movement for the privacy-conscious services to escape any regulation, not just choose the currently-politically-correct one. Like piracy sites did in 00-10s (abuse-proof hosting in Ecuador, shady domain registrar from SEA, zero search indexing) or crypto companies now (net of shell companies where not a single one is responsible for anything).

My point is, if you trust the company you're using, also trust it to use any means necessary to protect you from bad actors, don't rely on the laws here. Both the corporate and the state ones. If you don't trust it, don't give it anything you cannot afford to leak or lose.

Specifically, EU data protection laws are good to protect regular customers from the big corporations, but they offer little protection against the EU (and the member states) themselves. And if the risk you're hedging against is "yourself turning to big corp and abusing customers" moving to EU is okay, but not in any other case.

blitzar•7mo ago
> escape any regulation

You don't get to opt in to the laws you like and ignore the ones you don't like.

diggan•7mo ago
> You don't get to opt in to the laws you like and ignore the ones you don't like.

Well, maybe you shouldn't, or maybe you should, but you definitely can if you have the technical know-how. Probably best example is ThePirateBay which people and organizations have tried to take down for more than 20 years, yet it persists.

They're quite literally still alive while still choosing what laws they want to follow.

Obviously, that you can make this choice also means you get to chose if to even expose yourself to the potential consequences of that too, as Silk Road would attest to.

giancarlostoro•7mo ago
It helps that they don't generate nor host the content, they just maintain a database. TPB is basically a yellow pages for torrent content.
bee_rider•7mo ago
That might make sense from the point of view that only considers the service provider and the host.

> And if the risk you're hedging against is "yourself turning to big corp and abusing customers" moving to EU is okay, but not in any other case.

I mean, this seems like a silly concern (just don’t abuse the customers, lol). But, he can now reasonably offer to his customers the fact that he’ll be bound by EU privacy laws.

In the case of something like SourceHut which has consistently made decisions in favor of having a slow/sustainable business model instead of going for massive growth, this seems to make a lot of sense. He probably isn’t too worried about having to eventually backstab his customers, so why not make the value proposition clear?

Like what if the big plan here is to offer clear business terms backed by customer-friendly local laws and make a nice middle class salary for the rest of his life, while living in a nice friendly country?

stego-tech•7mo ago
> I'd wish there were movement for the privacy-conscious services to escape any regulation, not just choose the currently-politically-correct one.

Not possible. Anywhere that an entity is able to exist will also see some form of regulation. Regulation is the attempt of society to balance the benefits and harms of business such that its benefits reach as many people as possible, and its harms minimized or eliminated.

Too much regulation is just as bad as too little, and we have centuries of data demonstrating the need for a balanced approach.

As for the nod to piracy sites, what you’re suggesting is instead civil protesting of hostile regulations that harm society to benefit business interests. That’s excellent but the answer there is better regulations, not a lack of regulations.

that_guy_iain•7mo ago
All privacy-conscious services are already based in countries that have privacy-conscious laws.

And most privacy-conscious services generally protect you to a certain level by the amount of data they don't keep. Mulvad, for example, when raided kept everything they had. Because they could prove that the data that the warrant was for was not stored on their equipment. PRQ, they're quite happy to work with you without knowing who you are.

If you want to keep yourself private from law enforcement or intelligence agencies, then you shouldn't be using standard services without your own layer of encryption and privacy steps in between. You're always going to be at the behest of some government, that's just how the law works.

alephnerd•7mo ago
> Like piracy sites did in 00-10s (abuse-proof hosting in Ecuador, shady domain registrar from SEA, zero search indexing) or crypto companies now (net of shell companies where not a single one is responsible for anything).

And they were only able to do so under the auspices of corrupt politicians in said country. For example, Crypto firms in UAE purchasing property in projects closely affiliated with the Emirs of the Emirate they are domiciled in [0]. And Vietnam cracking down on shady domain registrars for streaming in order to unlock trading opportunities such as not being treated as a "Non-Market Economy".

Tech will always be subordinate to the government, and any techno-libertarian ideal faces that harsh reality fairly quickly.

[0] - https://www.occrp.org/en/project/dubai-unlocked

atoav•7mo ago
Sure go into some desert without them knowing and do your thing there. As soon as tou plan to interact with other people you will have to deal with the fact that societes like to create rules for themselves.

There is a word for people who like to unilaterally break social contracts for their own benefits and it has not a lot of positive connotations.

Note: that I totally get the sentiment of wanting to get away from all these complications especially in technically minded people. But the sooner we realize that this can either be lived political resistance or antisocial/sociopathic exploitation the better. Even in an ideal society individuals will have to be bound to certain rules, otherwise everybody will have to fear everybody else violating their boundaries. And different societies will find different forms of rules with different evaluations of how to do things.

TL;DR: Don't want to deal with the rules of a society? Don't interact with it. You cant have your cake and eat it too.

surgical_fire•7mo ago
I used those piracy websites, but there is some incredibly naivety in the thought that people trusted those.

I certainly trust governments where the rule of law applies more than I trust corporations. I certainly would not input any real data in a service hosted in Equador with a registrar in God-knows-where.

That does not mean that governments get unquestionable faith, but there's still the pretence that they protect their citizens. Corporations only seek profit.

jwilk•7mo ago
> shady domain registrar from SEA

What's SEA?

Benjaminsen•7mo ago
South East Asia
tarkin2•7mo ago
Any recommendations for cheap VPSs in Europe? The company should be basee in Europe, not just the server location.
CalRobert•7mo ago
Ovh is fine
homebrewer•7mo ago
Hetzner, Scaleway.
sigio•7mo ago
Can recommend both, but add netcup and layer7.net to those.
graemep•7mo ago
I tried a Scaleway dedi and it was very slow. Turned out storage IO was a problem. Just my experience with one product but it put me off them.

Many smaller providers too.

moooo99•7mo ago
To add to the other comments, had good experiences with Netcup and Contabo
nwellnhof•7mo ago
In the last years, many of the smaller German hosting companies were acquired by larger corporations. Netcup is owned by Anexia (Austria) now, Contabo was acquired by KKR (US), Hosteurope by Godaddy (US). If you're looking for hosting in the EU, you probably also want to avoid US-owned providers.
mcosta•7mo ago
> you probably also want to avoid US-owned providers.

Why?

immibis•7mo ago
They're subject to the same jaws that are the reason you don't host in the USA. Such as the CLOUD Act which compels them to give any days any time to the US government.

If you're doing business in the EU it's actually illegal to store the data about that business in the USA. It's not enforced though.

dewey•7mo ago
Hetzner and OVH are both great value for money, you'll find bad stories for every big hoster but they are professional (Someone will post the OVH fire story as a reply of that most likely, but that's not something that happens regularly) and a lot of the VPS resellers will sell you stuff that is hosted there too.
GardenLetter27•7mo ago
Hetzner has been amazing. I'd choose them regardless of the Europe requirement.
sunaookami•7mo ago
Adding my vote for Hetzner and Netcup!
jeroenhd•7mo ago
Leaseweb is quite cheap these days, though they seem to have stopped serving non-business customers. Budget hosts like Hetzner and Contabo may suffice, but make sure to check if they bothered to patch their servers (Contabo's EPYC servers are running on outdated microcode that allows leaking CPU cache between VMs for instance).

OVH is also popular but I found their network speeds kind of limiting. It's been a while since I last checked out their offerings, though.

jl6•7mo ago
I’m not sure which is worse, the impersonal, automated, regulatory padded cells of US gov/tech hegemons, or the potentially very personal attention of a local lord with very strong opinions[0].

[0] https://news.ycombinator.com/item?id=41837782

amiga386•7mo ago
If you do read Drew DeVault's The Stallman Report, please also consider reading the rebuttal at https://stallmansupport.org/ and perhaps consider reading the DeVault Report at https://dmpwn.info/
prasoon2211•7mo ago
This makes sense. And this is only accelerating - I talk to businesses in Germany and there's a genuine, non-insignificant number of people who want their data to be /physically/ in Europe.

Take this to its logical conclusion and basically, every company will need to segregate their data in regions. Most cloud platforms aren't really designed this way but it's coming.

There was a data locality law that India passed and Stripe had to do this massive migration project to segregate this data. I shudder to imagine what a more complex system would look like under such data locality laws.

CalRobert•7mo ago
I’m concerned about that being enough considering the CLOUD act. I want a company with no US ties