Country-Specific Operational Playbooks

What works in Lahore breaks in Cairo. What works in São Paulo breaks in Manila. The Delaware C-corp side of the cross-border stack is universal; the home-country side is not. This chapter is the country-by-country playbook for ten markets, each with its own regulator, FX regime, IT-export incentive, and operational stack.

Pakistan

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Entity. Single-Member Private Limited Company (SMC-Pvt Ltd) registered with Securities & Exchange Commission of Pakistan (SECP) under the Companies Act 2017. Online incorporation through SECP eServices portal: 3–7 working days; total fees PKR 25–60K (~$90–215). Mandatory follow-ons: PSEB (Pakistan Software Export Board) registration to unlock IT-export tax treatment; NTN/STRN from FBR; UBO disclosure.

FX & capital control. State Bank of Pakistan Foreign Exchange Manual (Chapters 13–14). Since the SBP October 2023 update, IT exporters can retain up to 50% of export proceeds (or USD 5,000/month, whichever is higher) in an Exporter's Special Foreign Currency Account (ESFCA) at HBL, Meezan, UBL, or Bank Alfalah. The remaining ~50% must be converted to PKR at the interbank rate. ESFCA funds can be used for permitted outward remittances (cloud bills, SaaS, dividend repatriation, overseas payroll) without case-by-case SBP approval.

IT export incentive. 0.25% final tax on export proceeds (Section 154A, ITO 2001) for PSEB-registered IT/ITES exporters, locked in until June 30, 2036 by Finance Act 2025. Non-PSEB-registered entities pay 1%. At least 80% of foreign earnings must arrive through approved banking channels. Salaries paid by PSEB-registered companies enjoy a 75% reduction on income tax.

Hiring engineers. 2025 market: junior PKR 60–120K/mo ($215–430); mid PKR 150–300K/mo ($535–1,070); senior PKR 350–600K+/mo (~$1,250–2,150). Statutory: EOBI at 5% employer / 1% employee on minimum wage; provincial social security (PESSI/SESSI) ~6% of wages; gratuity at one month per year of service; termination requires 30 days' notice or pay in lieu.

Banking gotcha. Mercury banned Pakistan-resident accounts in July 2024. Brex similarly restrictive. The workaround: keep a Mercury/Brex/Chase US business account with a non-Pakistan-resident director, receive customer payments there, then wire to your Pakistan ESFCA against an SBP Form-R. Wise Business still works. HBL and Meezan have the strongest international correspondent relationships.

Pitfalls. SECP UBO disclosure tightening; FBR transfer-pricing audits when intercompany cost-plus margins look under 7%; SBP scrutiny on outward remittances (every wire needs an "M-Form" filing); AML Act 2010 source-of-funds proof for any wire over $10K. Airlift's July 2022 collapse and Bazaar's Feb 2024 layoffs (~600 people) chilled VC sentiment but pushed SECP to launch LEAP and the Regulatory Sandbox with simplified compliance.

Stories. Wins: Sastaticket (Daraz/Alibaba acquisition), Cosmoz, Edraak, Tag, Oraan. Failures: Airlift, Truck It In, Bazaar Technologies (partial). The pattern: USD-revenue plays survived 2022–24 PKR crisis; pure-PKR-revenue plays got crushed.

India

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Entity. Indian Pvt Ltd under Companies Act 2013, registered with Ministry of Corporate Affairs (MCA) via SPICe+ form. Cost ₹15–35K; 7–15 days. Foreign holding via Delaware Inc permitted under the automatic route for IT/ITeS — 100% FDI allowed. DPIIT Startup India recognition unlocks tax holidays.

FX & capital control. Governed by FEMA 1999 under RBI. For an Indian founder personally owning a Delaware C-corp: Liberalized Remittance Scheme (LRS) caps remittances at USD 250,000 per individual per financial year, paired with Overseas Direct Investment (ODI) rules requiring Form ODI through an Authorized Dealer bank and an Annual Performance Report by December 31. Budget 2025 raised the TCS threshold from ₹7L to ₹10L/year. The "flip" is now subject to RBI's September 2024 framework allowing fast-track reverse-flip via NCLT.

IT export incentive. STPI/SEZ Section 10AA largely sunset on March 31, 2020 for new units. Today's path: GIFT City IFSC under Section 80LA — 10-year tax holiday (out of 15) for IFSC units. GIFT IFSC has 1,034+ registered entities as of Sept 2025.

Hiring engineers. 2025 (Bangalore +30–50%): junior ₹6–12 LPA ($7,200–14,400); mid ₹15–30 LPA ($18–36K); senior ₹30–60+ LPA ($36–72K+). Top product companies pay senior engineers ₹60–120 LPA in Bangalore. Statutory: EPF (12%/12% on basic up to ₹15K), ESIC (3.25%/0.75% on wages up to ₹21K), gratuity (4.81% accrual after 5 years), professional tax (~₹2,500/yr). ESOPs taxed at exercise as perquisite (slab rate), again on sale as capital gains; RSUs of US C-corps trigger TDS at vesting plus Schedule FA disclosure.

Banking. USD arrives via SWIFT into EEFC accounts at HDFC/ICICI/Axis/Kotak/Yes. Indian Pvt Ltds receive payments under STPI Softex form filed within 30 days of invoice. Wise Business and Razorpay's Cross-Border product are rising rails for SMBs.

Pitfalls. Section 56(2)(viib) — angel tax — abolished by Finance Act 2024 effective April 1, 2025. Legacy assessments still grind on; new fundraises are clean. RBI ODI pricing guidelines require DCF valuation. GST on cross-border services under IGST Section 13 (export of services is zero-rated but requires LUT filing). Permanent Establishment risk if Indian founder makes major business decisions while sitting in Bangalore.

Stories. Wins: Razorpay (flipped Delaware via Singapore, now unflipping for IPO 2025), Zomato/Eternal IPO, Freshworks (NASDAQ), Postman, Nykaa, Notion (Akshay Kothari co-founder). Restructures: BharatPe governance saga, GoMechanic March 2023 collapse.

UAE

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Entity. Free Zone Company (FZ-LLC or FZCO) in DMCC, ADGM, or DIFC — DMCC for general commercial/IT; ADGM/DIFC for fintech. AED 15–35K (~$4–9.5K) first-year licensing; 2–4 weeks. Mainland LLC via DED if you need to bill UAE customers in dirham.

Tax & FX. UAE Corporate Tax in force June 1, 2023 at 9% above AED 375,000. Free zones with Qualifying Free Zone Person (QFZP) status get 0% on Qualifying Income if non-qualifying revenue stays under 5% of total or AED 5M, whichever is lower. Capital fully convertible. From 2025, all QFZPs must file audited accounts.

Hiring engineers. Dubai 2025: junior AED 6–10K/mo, mid AED 12–20K/mo, senior AED 20–40K/mo + housing/transport allowances. EOSB: 21 days basic salary per year for first 5 years, 30 days for years 6+, capped at 2 years' wages. DIFC employees use DEWS instead of EOSB. No personal income tax.

Stack. Emirates NBD, Mashreq, ADCB, Wio. Mercury/Brex pair fine with NBD's US correspondent. Payroll via Bayzat or Deel.

Saudi Arabia

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Entity. LLC under MISA, with the RHQ program offering 30-year 0% corporate tax + 0% withholding tax (signed Dec 5, 2023). 350+ RHQ licenses issued by late 2025. Eligibility: subsidiaries/branches in 2+ jurisdictions excluding HQ and Saudi, mandatory + 3 optional activities, real Saudi premises, resident director.

Tax & FX. Mainland CIT 20% + 5% withholding on outbound dividends. Saudization (Nitaqat) imposes minimum % Saudi nationals. Vision 2030 incentives have shifted some industries faster than others.

Hiring engineers. Senior engineers earn SAR 18–35K/month. Termination requires "valid reason" and warnings; arbitrary termination triggers compensation = 15 days/year (open-ended) or remaining contract value (fixed-term).

Stories. Tabby ($4.5B October 2025 secondary; Saudi-UAE BNPL), Tamara (Saudi-based, restricted finance license from CBUAE Oct 2025).

Egypt

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Entity. Egyptian LLC ("S.A.E." or "WLL") under GAFI — 4–8 weeks, EGP 30–80K. GAFI's RiseUp 2025 opens free zones to service-exporting startups (~9,000 sqm of office space) with full customs and tax exemption, and a 2-hour electronic company setup path.

FX & capital controls. The 2024 EGP devaluation (USD-EGP 38% drop, March 6, 2024 flexible regime adopted with IMF $8B package) was traumatic but normalized FX availability. Repatriation delays remain a risk. Mitigant: keep operating expenses in EGP, revenues in USD, and remit USD through GAFI's free-zone framework.

IT export incentive. ITIDA Export-IT Program (13th round, registration extended to October 16, 2025): cash rebate of 35% micro / 15% small / 10% medium on value-added export proceeds; +5% for emerging tech (IoT, blockchain, cybersecurity); +5% for CMMI-3+; +10% for IPR-certified or operations outside Cairo/Giza/Alexandria. Eligibility requires ≥50% Egyptian ownership.

Hiring engineers. 2025: junior EGP 20–40K/mo ($400–800); senior EGP 50–90K/mo ($1,000–1,800). Remote-for-USD developers earn $40–120K USD/year — 5x local, which is why Egypt has a brain drain into US/EU remote payroll.

Stories. SWVL (NASDAQ via SPAC 2022, restructured 2023), Halan (Egypt's first unicorn, 2023), MaxAB, Khazna.

Vietnam

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Entity. LLC or JSC via Department of Planning and Investment (DPI). Investment Registration Certificate (IRC) + Enterprise Registration Certificate (ERC) required, ~6–10 weeks. Decree 320/2025/ND-CP (effective Dec 15, 2025): preferential 10% CIT for 15 years for qualifying tech/software (4-year exemption + 9-year 50% reduction). Software exports VAT 0%.

Hiring engineers. HCMC: junior $800–1,500/mo, senior $2,500–5,000/mo.

Stories. VNG, Tiki, MoMo, VNPAY, VNLIFE, Sky Mavis (six unicorns). VNG listed on NASDAQ in 2025 via Cayman holdco. Most use Singapore or Cayman holding companies for international fundraising.

Philippines

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Entity. SEC-registered domestic corp; PEZA registration grants holidays/reduced rates under CREATE Act. CREATE MORE Act (RA 12066), signed Nov 11, 2024: reduces RBE income tax from 25% to 20%, allows 50% WFH for PEZA-registered (100% for BOI), exempts BPOs from local business taxes for 7–17 years. IT-BPM industry hit $38B in 2024 revenue (+7% YoY).

Hiring engineers. Junior PHP 25–50K/mo ($450–900), senior PHP 80–200K/mo ($1,400–3,600).

Banking gotcha. Mercury banned Philippines-resident accounts in 2024 — same workaround as Pakistan.

Indonesia

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Entity. PT PMA (foreign-owned LLC) through OSS under BKPM Regulation No. 5/2025 (Oct 2, 2025). Minimum paid-up capital reduced to IDR 2.5B ($160K) but total investment value still IDR 10B per KBLI per project ($640K). Setup 4–6 weeks. Paid-up capital locked for 12 months.

Hiring engineers. Mid IDR 15–35M/mo (~$960–2,250).

Stories. GoTo, Tokopedia, Bukalapak (consolidated under GoTo).

Mexico

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Entity. S. de R.L. de C.V. or S.A. de C.V. through a fedatario público, registered with Registro Público de Comercio, RFC with SAT, CURP for individuals, IMSS for employees. 4–8 weeks, MXN 25–60K. USMCA makes Mexican-US cross-border services frictionless. No capital controls; peso-USD convertibility full.

Tax. Mandatory maquiladora safe-harbour (Article 182 LISR): greater of 6.5% of cost or 6.9% of asset value. APAs eliminated for FY 2025.

Hiring engineers. Junior $24–42K/yr USD; mid $30–54K; senior $42–72K. Mexico City has 320,000+ tech workers.

Pitfall. Mexico's 2021 outsourcing reform restricts pure staff-augmentation — your local entity must do actual work, not rent bodies. CFE (electricity) and STPS (labor) inspections are aggressive.

Stories. Kavak ($8.7B 2022), Bitso, Clip, Konfio, Stori ($1.2B 2022).

Brazil

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Entity. Sociedade Limitada (Ltda.) registered with JUCESP, CNPJ at Receita Federal. The "Cayman sandwich" is the default for VC-backed Brazilian startups: Cayman holdco → Delaware LLC → Brazilian Ltda. Nubank, QuintoAndar, Loft all use this structure.

FX & tax. Capital controls historically tight. BCB Resolution 520/2025 requires foreign-incorporated entities serving Brazilian customers to migrate to a Brazilian incorporated entity. 2025–26 tax reform introduces CBS/IBS VAT replacing PIS/Cofins/ICMS/ISS — major implementation pain through 2027.

Hiring engineers. Junior R$4–7K/mo ($800–1,400); mid R$96–168K/yr ($18–32K); senior R$168–240K/yr (~$32–46K). PJ contractors (using Simples Nacional) pay 6–10% effective tax versus CLT's 1.7–1.9x gross cost — most engineers prefer PJ. CLT requires 13th-month salary, FGTS (8% to severance fund), and 30 days vacation.

Stories. Nubank (Cayman holdco, NYSE-listed, $50B+ market cap), Loft, QuintoAndar, MadeiraMadeira.

Cross-country operational truths

After ten countries, the patterns:

Each country has its own playbook page with deeper detail, the specific 5-step recommended stack, and a curated reading list of local lawyers and service providers. The full list is at /manual. Direct links: Pakistan, India, UAE, Saudi Arabia, Egypt, Vietnam, Philippines, Indonesia, Mexico, Brazil.

Notes & sources

1. Pakistan Board of Investment — Tax Credit Regime for IT/ITES Exports
2. SBP Foreign Exchange Manual
3. RBI LRS — Master Direction
4. India Briefing — Abolishing Angel Tax
5. UAE FTA — Free Zone Persons CT Guide
6. EY — Saudi RHQ 30-year tax holiday
7. ITIDA — Export-IT Program
8. Vietnam Briefing — Decree 320/2025
9. DV Philippines — CREATE MORE Law
10. A&O Shearman — Indonesia BKPM Reg 5/2025
11. TPC Group — Mexico Maquiladora 2026
12. Latitud — Cayman Sandwich Structure