Pakistan
Wyoming
Wyoming will register an LLC for a founder in Lahore or Karachi for $100. Nothing in Wyoming law asks where you live.
The difficult half is at home. The State Bank of Pakistan decides whether a resident may hold a company abroad, the Federal Board of Revenue decides where that company is taxed, and two of the three main US fintech accounts list Pakistan as closed.
This page reads those rules in their own text, as published on 5 October 2026. Where the text does not settle a point, it says so.
The Wyoming side, in five lines
The US half is covered in the guides of this series. In short:
- Formation costs $100, then $60 a year, with no residence or citizenship condition. The steps are in forming a Wyoming LLC from abroad.
- A registered agent in Wyoming is compulsory, and for a foreign owner it is the main yearly cost. See Wyoming LLC cost.
- The EIN comes by phone, fax or post, because the IRS online tool needs a US tax number.
- Form 5472 is due every April, with a $25,000 penalty, even when no US tax is owed. See Wyoming LLC taxes for non-residents.
- None of the exclusions turns on Pakistan. Who is barred, and why, is in Wyoming LLC for non-residents.
What the State Bank allows a resident to own abroad
Under the Foreign Exchange Regulation Act, 1947, a resident needs a general or special permission of the State Bank to pay a person abroad or to acquire foreign securities. The general permissions are listed in Chapter 20, paragraph 13 of the Foreign Exchange Manual.
That paragraph was rewritten by FE Circular No. 01 of 11 July 2024. It allows residents, "including companies", to make equity investments abroad in five categories.
| Category | Who it is for | Limit |
|---|---|---|
| A1, IT companies | Companies in the IT sector opening a subsidiary or office abroad | Funds in their exporter account, or the higher of average net profit of three years and USD 100,000 |
| A2, other exporters | Export companies outside IT | Per year, the higher of 10% of average exports of three calendar years and USD 100,000 |
| B, holding company | A company under 7 years old, revenue below PKR 2 billion, equity below PKR 300 million | USD 10,000 of incorporation costs, then a share swap within 30 days |
| C, expansion | Companies incorporated in Pakistan | No ceiling, but prior State Bank permission |
| D, individuals | Resident individuals | Three narrow permissions, below |
Two conditions apply to every category. The destination country must allow profits and capital to be repatriated, which the United States does. The money must be "legitimate and tax paid", and the investor must be on the active taxpayer list.
The three permissions open to an individual
| Permission | Ceiling | Money sent from Pakistan |
|---|---|---|
| Shares of listed companies abroad | USD 25,000 a year, and 1% of the company | Yes |
| Employee share plan of a foreign group's Pakistani subsidiary | USD 50,000 a year, and 3% of the company | Yes |
| Sweat equity, shares received for work | 20% of the company | None |
Where a solo founder stands
Read the table again with a single-member Wyoming LLC in mind. The company is unlisted, you own 100% of it, and you are an individual.
- 1Is the owner a Pakistani company in IT or exports?Categories A1 and A2: a general permission through its bank, within the dollar limits
- 2Is it a young company raising capital abroad?Category B: a holding company abroad, USD 10,000 of costs, then a share swap
- 3Is it another Pakistani company?Category C: prior permission from the State Bank's Exchange Policy Department
- 4Is the owner an individual?Category D covers listed shares, employee plans and sweat equity up to 20%. Nothing covers 100% of your own unlisted company
- 5Outside every categoryA special permission, requested through an authorized dealer, before the investment
The sources diverge here, and the manual does not close the gap.
- What most formation guides say: nothing. They describe the US filing and treat the Pakistani side as free.
- What the manual says: equity investment abroad by a resident runs through paragraph 13, and no general permission in it fits a sole individual owner.
- What the manual does not say: how it treats an LLC formed with no capital, whose only cost is a $100 fee paid by card. That case is not named.
- What follows: put the question to your bank in writing before forming. The 1947 Act punishes a contravention with up to five years in prison, a fine, or both.
A Pakistani company you already run changes the answer. An IT company registered with the Pakistan Software Export Board can own the Wyoming LLC as a subsidiary under category A1, funded from its exporter account.
What you owe the State Bank once you hold it
- A return on form V-100, through your bank, within one month of acquiring the interest.
- Documentary evidence of the foreign company, within the same month.
- Audited accounts of the foreign company, each year, to the bank.
- Dividends and sale proceeds repatriated to Pakistan through banking channels and converted to rupees. They cannot be credited to a foreign currency account.
Freelancers and IT exporters: what your foreign currency account can pay for
Since EPD Circular Letter No. 17 of 23 October 2023, the manual has a paragraph for freelancers. It defines them as resident individuals providing digital services paid from outside Pakistan.
| Rule | What Chapter 12, paragraph 12 says |
|---|---|
| Retention | USD 5,000 a month or 50% of export proceeds, whichever is higher, in an Exporters' Special Foreign Currency Account |
| What a freelancer may pay from it | Personal and work payments of a current account nature: digital services, marketing, subscriptions, certifications |
| What an IT company may pay from it | All current account payments for its business, without prior approval |
| Equity investment abroad | Possible from the account, but only under Chapter 20, paragraph 13 |
| Transfers | Not to any other foreign currency account. Conversion to rupees at any time |
So the retained dollars can pay the registered agent or a software subscription. They do not create a right to own the company that those invoices belong to.
Two more points concern money that the LLC collects abroad.
- Section 10 of the 1947 Act forbids delaying the receipt of foreign exchange you are entitled to. Leaving client revenue in a US account with no end date is the conduct that section describes.
- The reduced tax on IT exports is collected by your bank in Pakistan. Section 154A sets 0.25% of proceeds for exporters registered with the Pakistan Software Export Board, for tax years 2024 to 2029, and 1% for other service exports.
- Whether a transfer from your own LLC counts as export proceeds was not found in the text. Ask before assuming the 0.25%.
How the FBR sees a Wyoming LLC
The United States treats a single-member LLC as transparent. Pakistan's Income Tax Ordinance has no such category, and three of its sections decide the outcome.
First, your own residence. Under section 82 you are resident if you spend 183 days or more in Pakistan in the tax year. Since the Finance Act, 2022, a citizen is also resident when not present in any other country for more than 182 days, or not a resident taxpayer of any other country. A resident is taxed on foreign income too.
Second, the company's residence. Under section 83, a company is resident in Pakistan when "the control and management of the affairs of the company is situated wholly in Pakistan at any time in the year". A Wyoming LLC run by one person from Islamabad meets those words.
Third, the controlled foreign company rule. Section 109A applies only to a company that is not resident. It attributes the company's income to its resident owner when all four conditions are met.
- Control: more than 50% held by residents together, or more than 40% by a single resident.
- Low tax: foreign tax paid is less than 60% of the tax the same income would bear in Pakistan.
- No active business income: broadly, the company does not earn most of its income from a business in its own country.
- Not listed on a recognised stock exchange.
| Reading | Section | Result for the profit |
|---|---|---|
| The LLC is managed wholly from Pakistan | 83(b) | A resident company, taxed in Pakistan on its income at company rates, 29% in the general case |
| The LLC is managed abroad and meets the four tests | 109A | Attributed to you each year and taxed at the dividend rate, 15% in the general case |
| The LLC falls below a threshold | 109A(6) and (7) | No attribution if you hold under 10%, or if its income is under PKR 10 million |
These readings compete, and we found no FBR ruling on a single-member LLC. What the three have in common matters more: none of them leaves the profit untaxed in Pakistan while you live there. A zero federal tax bill in the United States is the start of the Pakistani calculation.
The foreign income and assets statement
- Who files: every resident individual with foreign income of USD 10,000 or more, or foreign assets worth USD 100,000 or more (section 116A).
- What it shows: foreign assets and liabilities on the last day of the tax year, transfers during the year, foreign income and the expenses of earning it.
- The penalty: 2% of the foreign income or of the value of the foreign assets, for each year of default.
- The wealth statement under section 116 lists foreign assets as well, with no dollar threshold in its wording.
The 1957 treaty: old, in force, and narrow
The convention between the United States and Pakistan was signed on 1 July 1957 and has been in force since 21 May 1959. It has never been replaced, and it predates the LLC by two decades.
| Article | What it says | Use for a founder in Pakistan |
|---|---|---|
| II(1)(i) | A company is resident of Pakistan "if its business is managed and controlled in Pakistan" | Confirms the section 83 reading |
| II(1)(h) | A US corporation is a US resident only if it is not resident in Pakistan | An LLC run from Pakistan is poorly placed to claim treaty benefits as a US resident |
| III | Business profits are taxed in the other country only through a permanent establishment there | Protects a Pakistani business with no fixed base in the US |
| VI | US tax on dividends capped at 15% | Only for a Pakistani company holding more than 50% of the votes. Individuals keep the 30% rate |
| VIII | Royalties exempt in the source country | Useful for licensing income, if no permanent establishment |
| XV | Each country credits the other's tax | Services count as sourced where they are performed |
Two absences matter as much. There is no general article on interest, and nothing lowers the 30% US withholding on dividends paid to an individual. For a services founder with a transparent LLC and no US presence, the treaty changes little.
Banking and Stripe from Pakistan
Stripe does not list Pakistan among the countries where a business can open an account. PayPal's worldwide list does not include it either. That gap is the reason most founders look at a US company at all.
A Wyoming LLC applies to Stripe as a US business, and Stripe pays out to a US account. The account is where the plan is tested, and each provider publishes its own list.
| Provider | Test applied | Pakistan | Page read |
|---|---|---|---|
| Mercury | Where the founder lives | Listed as closed | Edited 30 Sep 2026 |
| Relay | Citizenship or residency of any owner | Listed as closed | Updated 11 Aug 2026 |
| Wise | Where the user is | Not listed | Undated, read 5 Oct 2026 |
| Payoneer | Not published | Serves Pakistan-based exporters, per its own site | Read 5 Oct 2026 |
- If you live in Pakistan, Mercury and Relay are both closed on their published rules. The remaining applications are Wise Business and Payoneer, and neither confirms in writing that it accepts a US LLC owned from Pakistan.
- Wise has a second list. Its general country list does not name Pakistan, but its page on US dollar account details lists Pakistan among the addresses where they are unavailable. Ask Wise in writing before relying on it.
- If you are a Pakistani citizen living in Dubai or London, Mercury's test is passed and Relay's is not, because Relay also reads the passport.
- "Not listed" is not an approval. Every provider reviews the file, and none owes you an account.
- What Stripe asks of a representative living in Pakistan was not read on a Stripe page. Do not treat the LLC as a guarantee.
The full comparison, the address rules and what to do after a refusal are in Wyoming LLC bank account for non-residents.
Resident in Pakistan, or Pakistani abroad
Almost every rule above turns on residence, and the two founders below share nothing but a passport.
| Resident in Pakistan | Pakistani living abroad | |
|---|---|---|
| State Bank investment rules | Apply in full | Aimed at residents. Confirm your status under the 1947 Act |
| Pakistani tax on LLC profit | Yes, under one of the three readings | Pakistan source income only, once non-resident |
| Foreign assets statement | From USD 100,000 of assets or USD 10,000 of income | Not as a non-resident |
| Mercury | Closed | Open to application |
| Relay | Closed | Closed, by citizenship |
One trap sits in the second column. Since 2022 a citizen who leaves Pakistan without becoming a tax resident of another country remains resident in Pakistan. A year spent moving between visas does not end Pakistani tax residence.
Where it goes wrong
- Forming first and asking the bank later. The State Bank question comes before the filing, and it costs nothing to ask.
- Assuming the freelancer account covers ownership. It covers payments, and sends equity back to paragraph 13.
- Planning around Mercury. Pakistan is on its list by residence, and on Relay's by passport as well.
- Reading zero US tax as zero tax. Section 83, section 109A and the foreign assets statement all reach a resident.
- Skipping Form 5472 because the LLC earned nothing. The penalty does not depend on revenue.
- Letting the company lapse. A dissolved LLC loses its account. The calendar is in Wyoming LLC annual report and compliance.
The bottom line
From Pakistan, the Wyoming filing is the easy part. The plan succeeds or fails on three questions that Wyoming never asks.
- May you hold it? Find your category in paragraph 13, or ask for a special permission, before forming.
- Where is it taxed? If you live in Pakistan and run it from there, expect Pakistani tax on the profit and a yearly statement.
- Where does the money land? Check the provider's list against where you live and which passport you hold.
A founder with a Pakistani IT company, or one who lives abroad, has a clean route. A resident freelancer acting alone has open questions to settle first, and they are cheaper to settle before the company exists. Once they are settled, the Wyoming LLC formation service covers the filing, the registered agent and the EIN.
Frequently asked questions
Can a Pakistani citizen own a Wyoming LLC?
Yes. Wyoming sets no citizenship or residence condition, and the exclusions that do exist do not turn on Pakistan. The limits come from Pakistan's foreign exchange rules if you are resident there, and from the banks.
Do I need State Bank of Pakistan permission to own a US LLC?
If you are resident in Pakistan, equity investment abroad runs through Chapter 20, paragraph 13 of the Foreign Exchange Manual. No general permission in it covers an individual owning all of an unlisted company, so the question should go to your bank before you form.
Can I fund the LLC from my freelancer foreign currency account?
You can pay current expenses from it, such as subscriptions and services. The manual says equity investment abroad from that account must still follow Chapter 20, paragraph 13.
Will a Wyoming LLC reduce my tax in Pakistan?
No. A resident is taxed on foreign income, a company managed wholly from Pakistan is itself resident there, and section 109A can attribute a foreign company's income to a resident who holds more than 40%.
Do I have to declare the LLC to the FBR?
A resident individual files a foreign income and assets statement once foreign income reaches USD 10,000 or foreign assets reach USD 100,000. The penalty for not filing is 2% of the income or asset value for each year of default.
Can I open a Mercury account from Pakistan?
Not on Mercury's published rule. Its page, edited on 30 September 2026, lists Pakistan as prohibited by country of residence. A Pakistani citizen living in a country that is not listed may still apply.
Does a Wyoming LLC give me Stripe?
It lets you apply as a US business, which a Pakistan-based business cannot do. Stripe still verifies the person behind the company and pays out to a US account, so approval is not automatic.
Does the US and Pakistan tax treaty help?
Very little for a solo founder. The 1957 convention caps US dividend tax at 15% only for a Pakistani company holding more than 50% of the votes, and it treats a company managed in Pakistan as a Pakistani resident.
Sources
- State Bank of Pakistan, Foreign Exchange Manual, Chapter 20, paragraph 13 (as amended by FE Circular No. 01 of 11 July 2024): the categories of equity investment abroad open to residents, their dollar limits, and the reporting duties that follow
- State Bank of Pakistan, Foreign Exchange Manual, Chapter 12, paragraph 12 (EPD Circular Letter No. 17 of 23 October 2023): freelancers and IT companies retain USD 5,000 a month or 50% of export proceeds, and what the retained funds may pay for
- Federal Board of Revenue, Income Tax Ordinance, 2001, amended up to 30 June 2026: sections 82 and 83 on residence, section 109A on controlled foreign companies, section 116A on the foreign income and assets statement, section 154A on export of services
- IRS, Taxation Convention with Pakistan, signed 1 July 1957, in force 21 May 1959: the residence definitions of Article II, the 15% dividend rate of Article VI and who can claim it
- Mercury, Prohibited countries (edited 30 September 2026): Pakistan is on the list, and the list is applied to country of residence, not citizenship
Official, read in full on 5 October 2026: Chapters 12 and 20 of the State Bank of Pakistan Foreign Exchange Manual and the Foreign Exchange Regulation Act, 1947, from the State Bank's archive site; the Income Tax Ordinance, 2001 as published by the Federal Board of Revenue, amended up to 30 June 2026; the 1957 convention as published by the IRS; the country lists of Mercury (edited 30 September 2026), Relay (updated 11 August 2026), Wise, Stripe and PayPal. Wyoming and federal figures are those of the guides in this series. Not confirmed on an official page and labelled as such in the text: how the State Bank treats a single-member LLC formed with no capital, how the Federal Board of Revenue classifies a disregarded LLC, how a transfer from your own LLC is taxed on arrival, and whether Payoneer or Stripe accept a US company owned by a resident of Pakistan. To reconfirm before acting: any State Bank circular issued after 11 July 2024, since the State Bank's current website could not be read, and every provider list, which changes without notice. This is not legal or tax advice.