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Comments
If you're seeing concurrent traffic, NGINX would probably be better. Else, if you're not having an issue, Apache should be fine.
I think it more depends on what flavor of PHP you use like php5 vs php5-cgi vs php5-fpm. php5-ftpm has been preforming well and before hand I was using php5-cgi on a server that had ALOT of traffic.
My philosophy on web servers is "Use nginx for everything, unless you have a compelling reason to use something else (such as a major incompatibility)". nginx works fine for WHMCS.
There is no best?
For WHMCS, I'd probably go with Apache, only because I'd want Mod_Security and your WHMCS install shouldn't have that much traffic where you need nginx.
I think Apache should be fine for most peoples requirements. Nginx is far better optimised though so if you expect a lot of business that in turn could amount to a lot of traffic then it might be worth going with nginx straight away.
It will save you headache in the long run.
Right now I've been utilizing NGINX with PHP-FPM. From my Apache installation and regular PHP. With just Apache and PHP, Blitz.io beat the hell out of the webserver. After 40 concurrent hits, it seized. Switched to NGINX and PHP-FPM and now can sustain 250 clients safely with minimal timeouts or drops.
But of course, your mileage may vary.
Use apache. Saving some MBs of RAM is not worth the hassle. Besides you probably want to have goodies like mod_rewrite, mod_security and .htaccess for your whmcs.
Use lighttpd on 384MB VPS. Works without problem.