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Pakistan · Tax position

How is a US LLC taxed for a Pakistani founder?

Pakistan does have a US income tax treaty — but it dates to 1957, decades before digital services existed. And Section 116A brings a foreign LLC squarely into FBR reporting.

Where Pakistan stands

Verified July 28, 2026

US–Pakistan tax treaty
Accepts

Pakistan appears on the IRS treaty index. The convention dates to 1957, so it predates modern services and digital income concepts entirely.

FBR foreign asset reporting
Excludes

Section 116A of the Income Tax Ordinance 2001 requires a resident individual to file a Foreign Income and Assets Statement once thresholds are crossed. A US LLC interest is a reportable foreign asset.

SBP prior permission
Excludes

Equity investment abroad by residents generally requires prior State Bank of Pakistan permission, with a specific route for startups and fintechs under FE Circular No. 01 of 2021.

US filing obligations
Accepts

A foreign-owned single-member LLC generally must file Form 5472 with a pro-forma 1120, whether or not tax is owed.

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A 1957 treaty is not a modern treaty

Pakistan is on the IRS treaty index, which sounds reassuring until you notice the convention dates to 1957. It predates software, digital services and most of how a modern founder earns money. Do not assume it delivers meaningful withholding relief on your particular income without a tax professional reading it against your facts.

Section 116A is the obligation that catches people

Under Section 116A of the Income Tax Ordinance 2001, a resident individual must file a Foreign Income and Assets Statement with the FBR once foreign assets or foreign income pass the prescribed thresholds. A US LLC interest is a foreign asset. This is a reporting duty that exists whether or not the company is profitable or active.

The SBP layer sits on top of all of it

Equity investment abroad by Pakistani residents generally requires prior SBP permission, and FE Circular No. 01 of 2021 created a specific route for startups and fintechs to establish holding companies abroad. Between SBP permission and FBR reporting, Pakistan has the most involved compliance stack of any market we cover.

Worth knowing before you buy

This is the most legally sensitive country page on this site. RazorFile is not a law firm or tax adviser and nothing here is advice. The combination of SBP permission and Section 116A reporting genuinely warrants a Pakistani tax lawyer before you form, not after.

Common questions

Pakistan has a treaty, so my tax is reduced?

Not something we can confirm. The treaty dates to 1957 and predates the kinds of income most founders earn. Whether it helps your specific situation is a question for a tax professional reading the convention against your facts — the treaty existing and the treaty helping are different things.

Do I have to tell the FBR about my LLC?

Section 116A requires resident individuals to file a Foreign Income and Assets Statement once the prescribed thresholds are crossed, and a US LLC interest is a reportable foreign asset. Whether you cross the threshold depends on your circumstances. This is a compliance obligation, not an optional disclosure.

Can I form the LLC first and sort SBP out later?

We would not advise it and we are not going to help you plan around it. Equity investment abroad generally requires prior SBP permission. The compliant sequence exists, there is a specific startup route under FE Circular No. 01 of 2021, and a Pakistani lawyer can tell you which applies to you.

Form your US LLC from Pakistan

Wyoming filing, Registered Agent, and EIN guidance. $100 state fee, filed in one to three business days.

RazorFile files companies. We are not a law firm, bank, or tax advisor, and nothing on this page is legal or tax advice.