US Payer Withholding · Pillar Guide

US Tax Treaty Withholding Rates by Country (2026)

Q: How does a treaty rate work?

A US income tax treaty assigns a maximum US withholding rate to specific income types paid to residents of the treaty partner country. The default chapter 3 rate under IRC 1441(a) is 30 percent on US-source FDAP. A treaty article on dividends, interest, royalties, or services overrides that default and sets a lower cap, often 0, 5, 10, or 15 percent. The reduced rate only applies when the foreign recipient delivers a valid Form W-8BEN (individual) or W-8BEN-E (entity) that claims the treaty benefit and identifies the article and rate. Without the W-8, the 26 CFR 1.1441-1(b)(1) presumption rules push the payment back to 30 percent regardless of what the treaty says.

Q: Does every payment to a foreign person qualify for a treaty rate?

No. A treaty only reduces withholding on income types the treaty article covers. Dividends, interest, royalties, and certain services are the common categories. Personal services income often has its own article with its own conditions, such as a day-count test or a fixed-base test. Some treaties have a limitation on benefits article that narrows the population of eligible residents. Income that is foreign-source is outside chapter 3 entirely and never needs a treaty. Income that is effectively connected with a US trade or business moves to net-basis taxation on Form 1040-NR or 1120-F, not the chapter 3 treaty rate. The starting point is always the income article in the actual treaty text, which the IRS publishes on its US Income Tax Treaties A-Z page.

Q: What is portfolio dividend vs direct dividend?

Most US treaties split the dividend article into two rates. The lower rate (often 5 percent) applies to a direct dividend, which is a dividend paid to a corporate shareholder that owns a meaningful percentage of the voting stock of the payer (often 10 percent or more). The higher rate (often 15 percent) is the portfolio rate that applies to all other dividends, including those paid to individual shareholders and to small corporate holders. The matrix on this page reports the rate the IRS lists in Publication 901 for the standard portfolio dividend column. Confirm the direct-dividend rate against the treaty text for the specific country before applying it.

Q: Why do some treaty rates show ranges?

Some treaty articles set different rates within the same income category depending on the underlying facts. Royalties is the most common example because most treaties split royalties into industrial royalties, copyright royalties, and film royalties, each with a different cap. Interest is sometimes split between bank interest and other interest. When the matrix shows a range like 0 to 10 percent, the row covers all subcategories in that treaty article. The payer has to read the article in the actual treaty text to pick the rate that fits the specific payment.

Q: What happens if there is no treaty?

The default 30 percent under IRC 1441(a) and 26 CFR 1.1441-1(b)(1) applies on the full gross payment of US-source FDAP. IRS Publication 901 reproduces the no-treaty rule in its opening pages: residents of countries that do not have an income tax treaty with the United States are subject to the statutory 30 percent rate on US-source FDAP unless the income is effectively connected with a US trade or business, in which case the foreign payee files a US net-basis return. Common no-treaty countries that come up in contractor work include Singapore, Vietnam, Argentina, Brazil (limited treaty coverage), and several Gulf jurisdictions. A W-8BEN from a no-treaty resident does not reduce the rate. The agent still has to collect the form so that the payee is documented as foreign.

Q: How often do these rates change?

Slowly. Treaty rates change when the United States and the partner country sign a new treaty or a protocol amending an existing one, and the change only takes effect after both legislatures ratify and the instruments of ratification are exchanged. That is a multi-year process. The IRS reflects the new rates in Publication 901 and the US Income Tax Treaties A-Z page after the protocol enters into force. The matrix on this page is verified against those two sources as of 2026-05-31. Re-verify before applying any rate on a high-value payment.

Q: Can a foreign payee claim a treaty rate without a US TIN on the W-8BEN?

Sometimes. The Form W-8BEN and W-8BEN-E instructions allow a foreign tax identification number (FTIN) issued by the payee's country of residence in lieu of a US TIN for most income types, with a narrow set of exceptions where a US TIN is still required (for example, certain treaty claims on dividends paid by REITs and a few other categories). The default position the payer should take is that an FTIN is acceptable for most contractor and royalty payments. Confirm against the current W-8BEN or W-8BEN-E instructions on the IRS forms page before relying on this for any specific payment.

Q: Does the payer have to file a separate IRS form to apply a treaty rate?

No special IRS form. The treaty rate is applied at the time of payment based on the W-8BEN or W-8BEN-E on file. The agent reports the reduced rate, the income code, the exemption code, and the treaty country on Form 1042-S at year-end, and the totals roll up onto Form 1042. The W-8 stays in the agent's records as the support for the rate that was applied. IRS NRA Withholding and the Form 1042-S instructions cover the reporting codes.

Reviewed by Omnivoo Compliance Team on May 31, 2026

The short answer

The United States has income tax treaties with around 65 countries. Treaty rates reduce the default 30 percent NRA withholding on dividends, interest, royalties, and certain services paid to residents of treaty countries. This matrix shows the reduced rates as of 2026-05-31, sourced from IRS Publication 901 and the IRS US Income Tax Treaties A-Z. Download the full table as CSV below. Rates are payer-side defaults under chapter 3. Confirm the recipient's beneficial-owner status with a valid Form W-8BEN or W-8BEN-E.

/ 01 · Download

The full treaty matrix as CSV.

64 treaty countries, last verified 2026-05-31. Re-verify against Publication 901 before applying any rate on a high-value payment.

CSV Download CSV treaty-rates-2026.csv · 64 rows

/ 02 · How to use this matrix

Three rules before you apply any number on this page.

The listed rate is the maximum reduced US-payer withholding. Each cell is the cap the treaty article sets on US chapter 3 withholding for that income type. The actual rate on a specific payment can be lower if the article carves out a subcategory (for example, copyright royalties at 0 percent while industrial royalties sit at 10 percent), and the agent has to read the treaty text to pick the right subcategory. The matrix is the starting point, not the final answer.

The recipient must give the payer a valid W-8BEN or W-8BEN-E claiming the treaty benefit. A treaty rate is not self-executing. The form has to be on file at the time of payment, has to identify the treaty country and the relevant article, and has to be the right version of the W-8 series for the payee type (W-8BEN for individuals, W-8BEN-E for entities). The agent records the rate, the income code, and the exemption code on Form 1042-S at year-end.

Without valid documentation the default 30 percent applies regardless of treaty. 26 CFR 1.1441-1(b)(1) requires the agent to reliably associate every payment with documentation upon which it can rely. A missing or expired W-8 sends the payment back to the presumption rules, which assume foreign payee, US-source FDAP, and the statutory 30 percent under IRC 1441(a). The treaty country on the invoice does not matter. The W-8 in the file does.

/ 03 · Treaty rate table

The 2026 matrix, sortable by column.

Click any column header to sort. Rates are the standard portfolio or default rates from each income article. Click the source link in any row to open the IRS page for that treaty.

Country	Dividends	Interest	Royalties	Services	Business Profits	Source
Armenia has NO bilateral US tax treaty. The US-USSR income tax treaty (1973) remains in effect for Armenia per IRS Pub 901 page 2 and IRS Armenia treaty page. In Table 1, the row "Comm. of Independent States*" applies. Verbatim: Interest=0 (footnote n), Dividends General=30, Dividends Direct=30 (Treaty Article=None), Royalties=0/0/0/0/0 (Article III(1)(a)). Footnote n: "The exemption applies only to interest on credits, loans, and other indebtedness connected with the financing of trade between the United States and the C.I.S. member. It does not include interest from the conduct of a general banking business." Per Pub 901: "Income that residents of a C.I.S. member receive for performing personal services in the United States is exempt from U.S. income tax if those residents are in the United States for no more than 183 days during the tax year." Per footnote aaa: countries to which USSR treaty applies have no direct dividend rate (30%).	n/a	n/a	n/a	n/a	Taxable only if PE in US (US-USSR treaty, applies to CIS members including Armenia until new bilateral treaty negotiated)	[IRS]
Rates reflect the 2001 Protocol. Original 1982 treaty had 15% dividends, 10% interest, 10% royalties; 2001 Protocol reduced direct dividends to 5% (for 10%+ ownership; 0% for 80%+ ownership subject to LOB) and royalties to 5%. Footnote nn: interest exempt if received by a financial institution or by the Australian government. Industrial equipment royalty rate is n/a (not treated as a royalty). Article 14 IPS exempts independent personal services unless the resident has a fixed base regularly available in the US or is present in the US for an aggregate of more than 183 days in the taxable year.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Verified verbatim from IRS Table 1 row: Austria AU — Interest 0 (general, footnotes g,jj,ss; Art. 11(1)); Dividends General 15 / Direct 5 (footnote w; Art. 10(2)); Royalties: Industrial equipment n/a, Know-How/Other Industrial 0, Patents 0, Film & TV 10, Copyrights 0 (footnote ss; Art. 12(1),(2)). Table 2 row confirms Austria Independent Personal Services Article 14, no time/compensation limit, exempt unless attributable to a fixed base in the US (footnote 7). Note: contingent interest not qualifying as portfolio interest is taxed at 30% (footnote jj). Treaty source: 1996 US-Austria Income Tax Treaty.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (Article 7)	[IRS]
Azerbaijan has no bilateral US tax treaty. It is covered by the 1973 US-USSR Income Tax Treaty per IRS guidance. Table 1 lists "Comm. of Independent States" with: Interest 0% (footnote n - applies only to interest on credits/loans financing US-CIS trade; NOT general banking interest, which falls to default 30%); Dividends 30% general / 30% direct (Treaty Article: None - explicitly noted "no direct dividend rate"); Royalties 0% across all categories per Art. III(1)(a). Table 2 grants exemption for Independent Personal Services up to 183 days under Art. VI(2). The treaty predates the OECD model; business profits provisions are limited compared to modern treaties.	n/a	n/a	n/a	n/a	Taxable only if PE in US (US-USSR 1973 treaty)	[IRS]
Bangladesh row from IRS Table 1: Interest 10% (Art. 11(2), footnotes g/bb/jj); Dividends 15% general/portfolio and 10% qualifying for direct dividend rate (Art. 10(2), footnote mm) - note 10% direct rate is unusually high vs. modern 5% treaties; Royalties 10% uniformly across industrial equipment, know-how/other industrial, patents, film & TV, and copyrights (Art. 12(2)). IPS exemption from Table 2 under Art. 15 requires presence <=183 days and Any contractor. Business profits taxed only with US PE under standard treaty structure.	n/a	n/a	n/a	n/a	Taxable only if PE in US (OECD model)	[IRS]
Verified verbatim from IRS Treaty Table 1 row for Barbados (BB): Interest 5% rr,z (Art. 11(1)/1PIV;2PII(6)); Dividends general 15% w,rr and direct 5% w,rr (Art. 10(2)/1PIII(1);2PII(6)); Royalties 5% rr across Know-How/Patents/Film&TV/Copyrights, with Industrial Equipment shown as 'n/a u rr' meaning U.S. statutory 30% applies (Art. 12(2)/1PV;2PII(6)). IPS per Treaty Table 2: Article 14 — exempt unless (a) regular base in US, (b) >=90 days presence in tax year, or (c) net income from US-resident payers exceeds USD 5,000. Business Profits Article 7: taxable in US only to extent attributable to a US permanent establishment. CRITICAL caveat (footnote rr): no treaty benefits for interest, dividends, or royalties if Barbadian recipient is subject to a special tax regime/administrative practice giving an effective tax rate substantially lower than the generally applicable rate (anti-IBC/anti-conduit rule from 2004 Protocol). Treaty also subject to Limitation on Benefits article.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Rates from the current 2006 treaty (in force since Dec 28, 2007), which superseded the 1970 treaty. Dividends Art. 10(2): 5%/15% standard tiers; Art. 10(3) provides 0% for 80%+ direct/indirect voting ownership (subject to LOB) and for qualified pension funds. Interest Art. 11(1) is fully exempt at source with narrow exceptions: 15% on contingent interest not qualifying as portfolio interest (Art. 11(2)(a)) and REMIC excess inclusions taxed at domestic rates. Royalties Art. 12(1) fully exempt at source. The 2006 treaty omits a separate Independent Personal Services article; services performed by a Belgian resident fall under Article 7 (Business Profits) and are exempt from US tax absent a US permanent establishment. Employment income (Art. 14) is taxed where exercised, with the standard 183-day/foreign-employer exception. Limitation on Benefits (Art. 21) applies to all reduced rates.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7); no separate IPS article in 2006 treaty	[IRS]
Rates verified verbatim from IRS Treaty Table 1: Interest 5% under Article 11(1)-(3) (footnotes g,dd,jj,z); Dividends 10% general / 5% direct under Article 10(2) (footnotes dd,mm); Royalties 5% across Know-How/Other Industrial, Patents, Film & TV, and Copyrights under Article 12(2)/P5(7); industrial equipment royalties n/a (covered by business profits under footnote u). Per Table 2 footnote 53, Independent Personal Services (Income Code 17) are treated as business profits under Article 7 — no separate IPS rate, exempt absent a US permanent establishment. Note: a 10% rate applies to contingent interest that does not qualify as portfolio interest (footnote jj).	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Direct verification from IRS Table 1 PDF: Interest 0 g,jj under Art. XI(1)/5P6(1); Dividends 15 mm general / 5 mm direct under Art. X(2)/5P5(1); Royalties split by type under Art. XII(2),(3)/5P7(1) - Industrial Equipment 10%, Know-How/Other Industrial 0%, Patents 0%, Film & TV 10%, Copyrights 0%. The 5P references denote the 5th Protocol (2007). For independent personal services, the original Article XIV was eliminated by the 5th Protocol; services now fall under Article VII (Business Profits) and are exempt absent a US permanent establishment.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (Article VII)	[IRS]
US-Chile treaty signed Dec 19, 2023; effective for withholding on payments made on/after Feb 1, 2024. Table 1 row for Chile (CI): Interest General 10% (Art. 11(1)-(10)); Dividends General 15%, Direct/Qualifying 5% (Art. 10(2)); Royalties — Industrial Equipment 2%, Know-how/Other Industrial 10%, Patents 10%, Film & TV 10%, Copyrights 10% (Art. 12(1)-(6)). Table 2: Independent personal services exempt for stays <183 days with no fixed base (Art. 14). Pub 901 confirms IPS exemption.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7, OECD-model)	[IRS]
The 1984 US-China treaty applies a single 10% rate to dividends (no portfolio/direct tier split), interest, and royalties. Interest paid to the Chinese government, central bank, or wholly government-owned financial institutions is exempt (Art. 10(3)). Royalties article (Art. 11(3)) covers copyright (literary/artistic/scientific, films/TV tapes), patents, know-how, trademarks, designs, secret formulas, and use of industrial/commercial/scientific equipment - all at the same 10% rate. Independent personal services (Art. 13) are taxable only in residence state unless the individual has a fixed base regularly available in the US or is present >183 days in the calendar year. Treaty does NOT apply to Hong Kong or Taiwan. Rates confirmed verbatim in IRS-hosted treaty PDF.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Verified verbatim against (a) IRS Cyprus treaty PDF: Article 12(2) caps US dividend tax at 15% (portfolio) and 5% (direct); Article 13(2) caps interest at 10% with exemptions in 13(3) for bank/government/sale-related interest; Article 14(1) reciprocally exempts royalties; Article 17 exempts independent personal services unless 183+ days presence or fixed base in US; Article 8(1) limits taxation of business profits to those attributable to a US permanent establishment. (b) IRS Table 1 (Rev. May 2023) Cyprus row confirms: Interest 10% (Art 13(2)), Dividends 15%/5% (Art 12(2)), all royalty categories 0% (Art 14(1)).	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Verbatim from IRS Table 1 row for Czech Republic (code EZ): Interest 0 (Art 11(1), footnote g - REMIC exclusion); Dividends 15 w (portfolio) / 5 w (direct, 10%+ ownership) Art 10(2), footnote w applies REIT/RIC carve-out; Royalties Art 12(2) — Industrial Equipment 10, Know-How/Other 10, Patents 10, Film & TV 0, Copyrights 0. Services and business profits drawn from the 1993 US-Czech Republic treaty: Article 14 (Independent Personal Services) exempts services absent a fixed base or 183+ days; Article 7 (Business Profits) follows OECD-model PE threshold. Footnote w: REIT dividend rate applies only to individuals holding <10% in the REIT.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Verified verbatim from IRS Table 1: Denmark (DA) - Interest 0% under Article 11(1) (footnotes g,jj); Dividends 15% general (portfolio) / 5% qualifying for direct dividend rate under Article 10(2) (footnotes dd,mm,oo); Royalties 0% across all categories (Industrial Know-How, Patents, Film & TV, Copyrights) under Article 12(1). Table 2: Independent Personal Services fully exempt with no limit under Article 14. Business profits taxable only if PE in US (OECD-model 2000 treaty as amended by 2006 protocol). Pension/annuity payments to Denmark residents: 30% general but 0% under grandfather rule (footnote c) for pre-March-31-2000 distributions; annuities exempt (footnote t).	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Direct dividend rate of 5% requires recipient corporation to own at least 10% of voting stock (Art. 11(2)(b)) and ≤25% of payor's gross income to be interest/dividends. Interest exempt at source if paid to/guaranteed/insured by a Contracting State or instrumentality (Art. 12(3)). Royalties: motion picture/radio/TV film royalties are treated as business profits (no withholding) under Art. 8(5) and Art. 13(2)(a). Independent personal services (Art. 15): exempt in US unless individual present 90+ days in the taxable year (note: differs from Pub 901's '89 days' phrasing, treaty text says 90+ days triggers taxation). Business profits taxable in US only if attributable to a US permanent establishment (Art. 8). This is the original 1980 treaty (still in force, no protocol updates).	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Verbatim from IRS Table 1 Estonia (code EN): Interest 10% (Art. 11(2), footnotes g,jj,z); Dividends General 15% w / Direct 5% w (Art. 10(2)); Royalties split — Industrial Equipment 5%, Know-How/Other 10%, Patents 10%, Film & TV 10%, Copyrights 10% (Art. 12(2)). Table 2: Independent personal services exempt up to 183 days (Art. 14); Dependent personal services exempt up to 183 days (Art. 15). Treaty signed Jan 15, 1998.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Verified verbatim from IRS-hosted treaty PDF. Article 10(2)(a) 5% direct (≥10% voting stock); 10(2)(b) 15% portfolio. Article 11(1) interest exclusively taxable in residence state (0% US source). Article 12(1) copyright royalties (literary/artistic/scientific including films/TV) exempt; Article 12(2) industrial royalties capped at 5%. Article 14 (Independent Personal Services) exempts service income unless attributable to a fixed base in the source state. The 2006 Protocol amended other provisions but the FDAP rate structure (5/15 dividends, 0 interest, 0/5 royalties) remains in force as reflected in IRS Pub 515/901 treaty tables.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Verified verbatim from IRS Table 1 France row: Interest 0 g,jj,ss (Art 11(2)); Dividends 15 mm general / 5 mm,oo,ss qualifying direct (Art 10(2) / 2P2); Royalties 0 ss across all categories - industrial equipment n/a u, know-how/other industrial 0, patents 0, film & TV 0, copyrights 0 (Art 12(1) / 2PIII). IRS Pub 901 confirms IPS exemption: residents of France performing independent personal services in the US are exempt from US income tax if they have no fixed base regularly available in the US (Art 14, no day or dollar limit per Table 2). Business profits taxable only with US PE per Article 7 (standard OECD model).	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Georgia is covered by the US-USSR Income Tax Treaty (signed June 20, 1973) via the Commonwealth of Independent States. Verified from IRS Tax Treaty Table 1 row "Comm. of Independent States*": interest 0% (footnote n - applies only to interest on credits/loans financing US-CIS trade; NOT general banking interest, which falls to default 30%); dividends 30% with no qualifying direct rate; all royalty categories 0%. Table 2 shows IPS exempt up to 183 days under Article VI(2). This is an older treaty (1973) that does not follow modern OECD model conventions; the dividend rate is notably high (no reduction from statutory 30%) and royalty rate notably low (full exemption). US payers should verify W-8BEN claims carefully due to treaty's unusual nature.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article III of US-USSR treaty)	[IRS]
Rates verified verbatim from IRS Table 1 row GM: Interest 0% Art. 11(1) [footnotes g, jj]; Dividends Portfolio 15% Art. 10(2)/PIV [dd, mm]; Dividends Direct 5% Art. 10(2)/PIV [dd, mm, oo]; Royalties 0% across Patents/Know-How/Film&TV/Copyrights Art. 12(1) [footnote ss applies for 15% if attributable to PE in third state]. Footnote jj: 30% applies for contingent interest not qualifying as portfolio interest. Treaty is the 1989 US-Germany Income Tax Treaty as amended by 2006 Protocol.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Art. 7). Per IRS Table 2 footnote 53, independent personal services for Germany are treated as business profits under Article 7 of the treaty.	[IRS]
The US-Greece treaty is the oldest in-force US income tax treaty (1950) and pre-dates the OECD Model dividends article. Critically, Article IX only exempts dividends paid by a GREEK corporation from US tax — it does NOT provide a reduced rate on US-source dividends paid to a Greek resident, so the statutory 30% FDAP rate applies to dividends from US payers. Interest exemption under Article VI does not apply to interest paid by a US corp to a Greek corp that controls >50% of the US payer's voting power. Royalty exemption under Article VII expressly does NOT apply to motion-picture film royalties (per Letter of Submittal). Verified verbatim against the IRS-published treaty PDF.	n/a	n/a	n/a	n/a	Taxable by US only if Greek enterprise has a permanent establishment in the US (Article III(1))	[IRS]
Current US-Iceland treaty is the 2007 Convention and Protocol (in force since 2008), which superseded the 1975 treaty. Rates shown reflect current IRS Treaty Table 1. Royalty rates are tiered: 0% for copyrights/patents, 5% for know-how/films/trademarks. Footnote 'ss' in Table 1 indicates the 5% rate applies to trademarks/industrial-commercial-scientific experience tied to a rental or franchise agreement. The 1975 treaty had a 15%/5% dividend regime and the 2007 treaty preserved the 15% portfolio/5% direct dividend structure while exempting most interest and most royalties. IPS Article 18 exempts independent personal services unless presence is ≥183 days/year or a fixed base is maintained (per Pub 901 Table 2: 89 days threshold also referenced for some categories).	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 8, 1975 treaty; 2007 treaty/protocol in force follows same OECD-model PE rule)	[IRS]
Verbatim from IRS Table 1 row for India (IN): Interest 15% [fn z, Art 11(2)]; Dividends General 25% [fn w, Art 10(2)]; Dividends Direct 15% [fn w, Art 10(2)]; Royalties Industrial Equipment 10% [fn x], Know-How/Other Industrial 15% [fn x], Patents 15% [fn x], Film & TV 15% [fn x], Copyrights 15% [fn x], all under Art 12(2)-(4). Footnote x: rate also applies to fees for included services (per May 15, 1989 MOU). Table 2 (IPS, Art 15): exempt if presence in US <= 89 days, any contractor, no compensation limit. The 25% dividend portfolio rate is notably higher than most modern US treaties (which use 15%) because the US-India treaty dates to 1989 and has not been updated. Business profits per Article 7 are taxable only if attributable to a US permanent establishment (Article 5).	n/a	n/a	n/a	n/a	Taxable only if a Permanent Establishment exists in the US (Article 7, US-India treaty)	[IRS]
1988 US-Indonesia treaty in force. Dividends: single 15% rate under Art. 11(2) — no portfolio/direct tier split. Branch profits additional tax under Art. 11(4) also capped at 15%. Interest: 15% under Art. 12(2); exemption under Art. 12(3) only for interest paid to the other Contracting State or its tax-exempt agency/instrumentality. Royalties under Art. 13(2): 15% for paragraph 3(a) royalties (copyrights of literary/artistic/scientific works, motion pictures, patents, designs, models, plans, secret processes/formulas, trademarks, industrial/commercial/scientific know-how) and 10% for paragraph 3(b) royalties (industrial, commercial, or scientific equipment rental). Independent personal services (Art. 15): exempt from US tax unless the resident has a fixed base in the US or is present in the US 120+ days in any consecutive 12-month period (note: 120-day threshold, not the more common 183-day rule). Business profits (Art. 8): only taxable in the source state if attributable to a PE there.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Art. 8); OECD-model PE rule	[IRS]
Verified verbatim from IRS Table 1 (Rev. May 2023): Ireland (EI) shows Interest 0% (Art. 11(1)) with footnotes g,jj,ss; Dividends general 15% mm (portfolio) and 5% mm,ss qualifying for direct dividend rate (Art. 10(2)); Royalties 0% ss across know-how/patents/film & TV/copyright (Art. 12(1)), industrial equipment n/a u (covered as business profits). Independent Personal Services (Art. 14): residents of Ireland are exempt from US tax on services as independent contractors unless they have a fixed base regularly available in the US (per Pub 901 narrative). Business profits (Art. 7): US may tax only if attributable to a PE. Footnote 'ss' indicates a Limitation on Benefits provision must be met; 'g' excludes REMIC excess inclusions; 'jj' relates to contingent interest. Treaty is the 1997 Convention as amended by the 1999 Protocol.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7, OECD model)	[IRS]
Treaty effective 1 January 1995. Dividends Art. 12(2): 25% portfolio cap, 12.5% if recipient corp owns >=10% voting stock and <=25% of payor's gross income is interest/dividends. Interest Art. 13(2): 17.5% general, 10% for bank/savings/insurance lender; gov-guaranteed interest exempt. Royalties Art. 14(1)(b): 15% industrial (patents, designs, secret processes, trademarks), 10% copyright/film. IPS Art. 16: exempt unless 183+ days. Business profits Art. 8(1): PE required. Note Israel dividend/interest rates are higher than most modern US treaties; Israel has higher general rates as an exception to standard policy.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 8)	[IRS]
Italy row from IRS Table 1 verbatim: Interest 10% (Art. 12(2), footnotes g,h - exemptions for sale of goods/services between enterprises and qualified governmental entities); Dividends 15% portfolio / 5% direct (Art. 10(2), footnote mm re RIC/REIT); Royalties (Art. 12(2)): industrial equipment 5%, know-how/other industrial 8%, patents 8%, film & TV 8%, copyrights 0%. Per footnote tt, computer software royalties in Italy are taxed at the industrial equipment rate (5%), not the copyright rate. Independent Personal Services governed by Article 14 of the 1999 treaty - exempt unless services performed through a fixed base regularly available in the US. Business profits per Article 7 - taxable in US only if attributable to a US permanent establishment.	n/a	n/a	n/a	n/a	Taxable only if attributable to a permanent establishment in the US (Article 7)	[IRS]
Rates verbatim from IRS-hosted treaty PDF: Art. 10(2)(a) 10% direct, Art. 10(2)(b) 15% portfolio, Art. 11(2) 12.5% interest, Art. 12(2) 10% royalties. Treaty preamble: "Interest is taxable at the source at a maximum rate of 12.5 percent... Royalties, including motion picture royalties, are subject to a maximum rate of tax at source of 10 percent." Interest exempt if received/guaranteed/insured by a Contracting State. IPS (Art. 14) exempts services unless thresholds met. Treaty is the 1980 convention, still in force.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Art. 7, OECD model)	[IRS]
From IRS Table 1: Japan row reads "10 e,g,dd" interest (Art 11(2)); dividends "10 dd,mm" general and "5 dd,mm,oo" qualifying (Art 10(2)); royalties all 0 (Art 12(1)). Note Table 1 lists 10% portfolio dividend rate (lower than many US treaties); 5% direct dividend rate requires ownership threshold (generally 10% of voting stock - footnote b). Interest has broad Japan-specific exemptions (footnote e): financial institutions, sale-on-credit indebtedness, government entities, and pension funds. Royalties are fully exempt (0%) across all categories under Article 12(1) of the 2003 treaty as amended by 2013 protocol. Independent Personal Services for Japan in Table 2 carries footnotes 8 and 53 - footnote 53 means "Treated as business profits under Article 7 of the treaty," so services are exempt absent a PE in the US.	n/a	n/a	n/a	n/a	Taxable only if attributable to a permanent establishment (PE) in the US - Article 7	[IRS]
Verified verbatim from IRS Tax Treaty Table 1 row "Kazakhstan KZ": Interest 10 (g, z) per Art. 11(2); Dividends 15 ff (general/portfolio) and 5 ff (qualifying direct, 10%+ voting stock) per Art. 10(2); all royalty categories (industrial equipment, know-how, patents, film/TV, copyrights) 10% per Art. 12(2). Footnote uu: beneficial owner may elect to compute tax on a net basis as if attributable to a US PE. Footnote ff: REIT dividends subject to 30% rate (not 15%). Table 2: Independent personal services exempt up to 183 days under Article 14 with no fixed base; per Pub 901, also requires income not attributable to a fixed base regularly available in the US. Business profits follows OECD model (PE threshold). Treaty signed 1993.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment	[IRS]
Kyrgyzstan is covered by the U.S.-U.S.S.R. income tax treaty (signed June 20, 1973) via CIS succession, per IRS Pub 901 and Table 1 footnote *. Verbatim from IRS Table 1 C.I.S. row: Interest 0 (footnote n — trade-finance only), Dividends 30 / Direct 30 (Treaty Article: None — no reduced dividend rate), Royalties 0 across all categories (Art. III(1)(a)). Verbatim from IRS Table 2 C.I.S. row: Independent personal services exempt up to 183 days under Art. VI(2) with no compensation cap. No portfolio/direct dividend split — both are 30%. IRS Pub 901 footnote bbb confirms "countries to which the U.S.S.R. treaty applies—30% (no direct dividend rate)".	n/a	n/a	n/a	n/a	Taxable only if attributable to a US "representation" (treaty equivalent of PE) under Art. III; otherwise exempt	[IRS]
Treaty effective 1 January 2000. Article 10(2): 5% if beneficial owner is a company holding directly at least 10% of voting shares; 15% in all other cases. Article 11(2): 10% max; exemptions for government, central bank, and certain trade-credit interest. Article 12(2): 5% for industrial/commercial/scientific equipment royalties; 10% for all other royalties (including copyright, patent, software, film). Article 14: IPS exempt unless services performed via a fixed base in US or stay exceeds 183 days in any 12-month period. Article 7: Business profits taxable in US only if attributable to a permanent establishment. Rates verified verbatim against IRS-hosted treaty PDF.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
All rates extracted verbatim from IRS treaty PDF. Dividends Art. 10(2): 5% if beneficial owner is a company holding directly at least 10% of voting shares; 15% in all other cases. Interest Art. 11(2): 10% (with exemptions for govt-derived interest and sale-on-credit interest). Royalties Art. 12(2): 5% for use of industrial/commercial/scientific equipment; 10% in all other cases. IPS Art. 14: taxable only in residence state unless individual has a fixed base in US or stays 183+ days in any 12-month period. Business profits Art. 7: taxable only if attributable to a US PE.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Art. 7)	[IRS]
Luxembourg row in IRS Table 1: Interest 0 (Art. 12(1)); Dividends 15% general / 5% direct (Art. 10(2)); Royalties 0% across all subtypes - know-how/other industrial, patents, film & TV, copyrights (Art. 13(1)); Industrial Equipment marked n/a (covered by Business Profits article when from leasing in a trade or business). Footnote w: 15% rate applies to RIC/REIT dividends with limits. Footnote ss: 15% rate applies if income is attributable to a PE in a third state with low effective tax. Footnote u: equipment leasing income covered by Business Profits article. Pub 901 confirms independent personal services performed by a Luxembourg resident in the U.S. are exempt unless the resident has a fixed base regularly available in the U.S.	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Verified verbatim against IRS Tax Treaty Table 1 (Rev. May 2023) Malta row: Interest 10% (Art. 11(2)); Dividends 15% general / 5% direct (Art. 10(2)); Royalties (Know-how/Patents/Film & TV/Copyrights) all 10% (Art. 12(2)). Industrial Equipment royalties shown as "n/a u" (no separate category). Per IRS Treaty Table 2, Independent Personal Services for Malta is Code 17 with footnote 53: "Treated as business profits under Article 7 of the treaty" - so services exempt unless attributable to a US PE.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Rates verified verbatim from IRS Table 1 PDF (Mexico row, line 79: "MX 15 g,dd,hh \| 11(2) \| 10 dd,mm \| 5 dd,mm,oo \| 10(2) / 2PII \| 0 \| 19(1)(a)") and royalties row (line 170: "MX 30 \| 19(1)(b) \| 10 \| 10 \| 10 \| 10 \| 10 \| 12(2)"). IPS rule confirmed from IRS Table 2 (line 383: "Mexico \| 17 \| Independent personal services \| 182 days \| Any contractor \| No limit \| 14"). Footnote hh details the interest rate variations specific to Mexico. The 10/5% dividend split follows the standard OECD model with the 5% direct rate applying where the beneficial owner is a company holding at least 10% of voting stock.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (Article 7, OECD-model business profits rule)	[IRS]
There is no bilateral US-Moldova income tax treaty. Per IRS Pub 901 (9-2024, p.2): "The U.S.-U.S.S.R. income tax treaty remains in effect for the following members of the Commonwealth of Independent States (C.I.S.): Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan." The 1973 USSR Convention is unusual: it contains NO dividends article (so statutory 30% withholding applies to dividends paid to Moldova residents). Royalties/know-how/copyrights are fully exempt under Article III(1)(a). Interest is only exempt when tied to trade-finance credits per Article III(1)(g); other interest has no reduced treaty rate and defaults to 30%. Independent personal services are exempt if the individual is in the US no more than 183 days in the tax year (Article VI(2) and Pub 901 "Commonwealth of Independent States" section). Business profits are taxable in the US only if earned through a "representation" (the treaty's PE-equivalent) per Article IV. Treaty rates verified verbatim from IRS-hosted treaty PDF and Pub 901.	n/a	n/a	n/a	n/a	Taxable only if conducted through a "representation" (PE-equivalent) in the US per Art IV; sales through brokers/commission agents exempt under Art III(1)(e)	[IRS]
Verified verbatim from IRS Tax Treaty Table 1: Morocco (MO) row shows Interest General 15% (footnote z, Treaty Art. 11(2)); Dividends Paid by U.S. Corporations - General 15% (portfolio), Qualifying for Direct Dividend Rate 10% (Treaty Art. 10(2)); Royalties all subcategories (Know-how/Other Industrial, Patents, Film & TV, Copyrights) 10% (Treaty Art. 12(2)), Industrial Equipment n/a. Independent Personal Services exemption from Pub 901: residents of Morocco performing services in US are exempt if (1) ≤182 days during tax year AND (2) no fixed base maintained for >89 days. Treaty in force since 1977.	n/a	n/a	n/a	n/a	Taxable only if PE in US (1977 US-Morocco Income Tax Treaty)	[IRS]
Verified verbatim from IRS Table 1: Interest 0 (Art 11(1) — note refers to col header; treaty cite is 12(1)), Dividends 15 portfolio / 5 direct (Art 10(2)), all royalty subcategories 0 (Art 13(1)); industrial equipment shown as 'n/a' (covered elsewhere). Footnote 'ss' indicates anti-abuse/LOB-style conditions, 'pp' relates to dividend qualification. From Table 2: Independent Personal Services exempt under Art 15 with no day/amount limit, unless attributable to a US fixed base (footnote 7). Business profits exempt absent a US PE per OECD-model approach. Always review treaty + 2004 Protocol + LOB before applying.	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Verified verbatim from IRS Table 1 PDF: NZ row shows Interest 10% (Article 11(2)/PVII, footnotes g, jj, z), Dividends General 15% mm and Direct Dividend 5% mm,oo (Article 10(2)/PVI), Royalties 5% across Know-How/Other, Patents, Film & TV, and Copyrights (Article 12(2)/PVIII). Industrial equipment royalties marked n/a u (covered by Business Profits). From IRS Table 2: Independent Personal Services (Code 17, Article 14) - 183 days maximum US presence, no compensation limit. Footnote 53 indicates the IPS article was removed by the 2008 Protocol and folded into Business Profits (Article 7) - so for residents under the post-2008 regime, services income is taxable only if there's a PE in the US. Underlying authority: 1982 US-NZ Income Tax Treaty as amended by 2008 Protocol.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7)	[IRS]
Verbatim Norway row from IRS Table 1 (Rev. May 2023): Interest 0% (footnote s — reciprocal exemption), Dividends Paid by US Corps 15%, Qualifying for Direct Dividend Rate 15% (Art. 8(2)/PIV(1) — Norway is one of the older treaties where direct rate is not reduced below portfolio), Royalties all 0% under Article 10(1) (industrial equipment and film/TV are n/a — covered under business profits net basis if PE/fixed base exists). Table 2: Independent Personal Services exempt under Article 13 unless contractor maintains fixed US base for more than 182 days. Treaty is the 1971 US-Norway Income and Property Tax Convention with 1980 Protocol.	n/a	n/a	n/a	n/a	Taxable only if PE in US (older 1971 treaty model with 1980 protocol)	[IRS]
Pakistan-US treaty is from 1957 and unusually unfavorable: NO reduction for interest (30% statutory applies) and NO reduction for portfolio dividends (30%); only direct dividends (10%+ voting stock ownership) qualify for 15% under Article VII(2)/VI(1). Royalties are exempt (0%) for industrial royalties/know-how, patents, and copyrights under Article VIII(1), but per footnote u, TV broadcasting rights ARE covered by the Royalty article while rental income from motion picture films is NOT. Industrial equipment leasing falls under Business Profits (net basis) not the Royalty article. For services: 1957 treaty has Personal Services article (XI) with typical PE/fixed-base and short-stay exemption, and Business Profits (Article III) taxable only if attributable to a US PE.	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article III, 1957 treaty)	[IRS]
Treaty is the 1976 US-Philippines Income Tax Convention (one of the oldest still in force). Table 1 Philippines row: Interest 15% (Art. 12(2)), Dividends 25% general / 20% direct (Art. 11(2)), Royalties 15% across all categories (Art. 13(2)) - footnote vv applies. Table 2 row 17: Independent Personal Services exempt under Art. 15 if presence does not exceed 89 days in tax year. Business profits taxed only with US PE per treaty Art. 8. Rates are notably higher than most modern US treaties (e.g., interest 15% vs. 0% common elsewhere) because the treaty has never been renegotiated/protocol-updated.	n/a	n/a	n/a	n/a	Taxable only if US PE (Article 8, OECD-style PE threshold)	[IRS]
Rates from the 1974 US-Poland income tax treaty still in force per IRS Table 1 (Rev. May 2023). Interest 0% (Art. 12(1)); Dividends 15% portfolio / 5% direct dividend rate (Art. 11(2)); Royalties 10% uniform across know-how/other industrial, patents, film & TV, and copyrights (Art. 13(2)); Industrial equipment royalties shown as 'n/a u' (treated under business profits article). Independent personal services exempt under Art. 15 if US presence does not exceed 182 days. The newer 2013 US-Poland treaty was signed but has NOT been ratified by the US Senate as of the IRS table publication date, so the 1974 treaty remains in effect.	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
US-Portugal Income Tax Treaty (1994, in force since 1995) confirmed active on IRS A-Z list with no suspension/termination notice. Per IRS Table 1: Portugal entry shows interest 10% (footnotes g, jj, z; treaty Article 11(2)), dividends 15% portfolio / 5% direct (Article 10(2)), royalties 10% (Article 13(2)). REIT dividends use 15% only if beneficial owner is individual holding <25% interest (footnote w - Portugal-specific threshold). Per IRS Table 2: Independent personal services exempt up to 182 days under Article 15. Business profits taxable only with US PE per Article 7. Adversarial check passed: all rates extracted directly from IRS-published PDF tables.	n/a	n/a	n/a	n/a	Taxable only if PE in US (OECD-model Article 7)	[IRS]
US-Romania 1973 income tax treaty is in force; Romania appears on the IRS A-Z list with no suspension/termination caution and is included in IRS Table 1 (Rev. May 2023). Dividend column has a single 10% rate in both the general and direct dividend columns - no preferential direct-investment tier. Interest 10% with footnote z (reduced/exempt for government, banks, financial institutions, gov-guaranteed loans, commercial credit - per treaty Art. 11(2)). Royalties split: 15% for industrial royalties (know-how, patents) and 10% for cultural royalties (film, TV, copyrights including software per footnote tt) under treaty Art. 12(2). Industrial Equipment is n/a (footnote u: covered by Business Profits or Other Income article, not Royalties). A modernized 2024 protocol was signed but is not yet listed by IRS as effective; the 1973 treaty remains the operative document as of 2026-05-31.	n/a	n/a	n/a	n/a	Taxable in US only if attributable to a US permanent establishment (1973 treaty business profits article)	[IRS]
US-Slovak Republic Income Tax Treaty (signed 1993) is in force as of 2026-05-31; listed without caution on the IRS A-Z treaty page (contrast Russia "Partially Suspended" and Hungary "Terminated"). Rates verified from IRS Table 1 (Rev. May 2023): Interest 0% [Art. 11(1)]; Dividends 15% general / 5% qualifying direct [Art. 10(2)]; Royalties split [Art. 12(2)] — industrial equipment, know-how/other industrial, and patents all 10%; film & TV and copyrights 0%. Pub 901 confirms independent personal services are exempt absent a US permanent establishment.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (OECD model, Article 7)	[IRS]
US-Slovenia income tax treaty signed 1999, in-force as of 2026-05-31. IRS A-Z page lists Slovenia with no suspension/termination flags (unlike Belarus, Hungary, Russia). Interest 5% per Article 11(2) with footnotes g/z/jj (REMIC exclusion, government/financial-institution exemptions, contingent interest at 15% may apply). Dividends 15% portfolio / 5% direct per Article 10(2) (RIC/REIT special rules per footnote mm). Royalties 5% across all categories per Article 12(1). Industrial equipment royalties covered under Business Profits article (footnote u, n/a). Independent personal services / business profits taxable in US only if attributable to a US permanent establishment per OECD-model treaty structure.	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
US-South Africa income tax treaty signed 1997 confirmed IN FORCE as of 2026-05-31 per IRS country page and IRS A-to-Z list (no termination, suspension, or CAUTION notes - unlike Belarus, Hungary, Russia). Source: IRS Table 1 row for South Africa (country code SF): interest 0% (notes g, jj for portfolio/bank interest exemption); dividends Article 10(2) 15% portfolio / 5% direct (note w - direct rate requires >=10% voting stock ownership); royalties Article 12(1) 0% (note f - all categories). Table 2 confirms IPS exemption under Article 14 (183-day test, any contractor, no compensation limit). Pensions taxed at 15% (note l - reduced rate if not subject to early-withdrawal penalty). Withholding-agent default rate without W-8BEN treaty claim remains statutory 30%.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (OECD-model Article 7)	[IRS]
US-South Korea Income Tax Convention (signed 1976, in force since 1979) is active as of 2026-05-31 - no termination or suspension noted on the IRS A-Z treaty page. Verified directly from IRS Tax Treaty Table 1 PDF: Korea, South (KS) row shows interest 12% (Art 13(2)), dividends general 15% / direct 10% (Art 12(2)), royalties patents/know-how 15%, film & TV 10%, copyrights 10% (Art 14(1)). Note: industrial equipment royalties marked "n/a u" (no specific treaty rate; default 30% applies). Independent personal services (Article 18) require BOTH presence <=182 days AND compensation <=$3,000 p.a. to be exempt - a relatively low threshold compared to many newer treaties.	n/a	n/a	n/a	n/a	Taxable in US only if attributable to a US permanent establishment (OECD-model business profits article)	[IRS]
US-Spain treaty (1990) in force; significantly upgraded by 2013 Protocol (Technical Explanation 2014) which reduced interest and royalties to 0% and refined dividend rates. Spain confirmed in-force on IRS A-Z page (no termination/suspension caution). Dividend footnotes dd/mm/oo specify 5% direct rate generally requires 10% ownership; footnote zz adds anti-abuse rule for third-state PEs.	n/a	n/a	n/a	n/a	Taxable only if PE in US (OECD-model, Article 7, as amended by 2013 Protocol)	[IRS]
US-Sri Lanka income tax treaty signed 1985 with 2002 Protocol; confirmed in force on IRS A-Z list with no suspension/termination notice as of 2026-05-31. Dividend rate has no preferential direct-dividend tier - both portfolio and qualifying direct dividends are 15% (Article 10(2)). Footnote gg notes special conditions for REIT dividends. Interest 10% under Article 11(2) / Protocol VIII (footnotes g, jj, z apply standard exemptions for governmental/bank interest). Royalties under Article 12(2): 5% for rental of tangible personal property (footnote y), 10% for all other categories. IPS exempt under Article 15 with 183-day presence test; Business Profits follow Article 7 (PE-based taxation).	n/a	n/a	n/a	n/a	Taxable only if PE in US (OECD-model treaty)	[IRS]
Treaty in force: original 1994 income tax treaty as amended by the 2005 protocol. Not on IRS terminated/suspended list (unlike Hungary, Russia, Belarus). Dividend direct rate of 5% requires 10%+ voting stock ownership; certain qualifying pension funds may receive 0% on dividends if holding-period conditions are met (Table 1 footnotes dd, mm, oo). Interest 0% rate has standard exclusions (footnotes g, jj) including contingent interest treated as dividends under the protocol.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (OECD-model Business Profits article)	[IRS]
US-Switzerland treaty in force: 1996 convention as amended by 2009 protocol (entered into force 2019). Table 1 row SZ: Interest=0 (general); contingent interest that does not qualify as portfolio interest is taxed at 30% (footnote jj). Dividends: 15% portfolio / 5% qualifying direct dividend rate (treaty Art. 10(2)). Royalties Art. 12(1): Industrial Equipment n/a, Know-how/Other 0%, Patents 0%, Film & TV n/a, Copyrights 0%. Table 2 row SZ: Independent personal services Art. 14, no time/dollar limit, any contractor; exempt unless attributable to a fixed US base (footnote 7). Business profits per OECD-model Art. 7 — taxable in US only if attributable to a US permanent establishment.	n/a	n/a	n/a	n/a	Taxable only if PE in US	[IRS]
Tajikistan has NO bilateral U.S. tax treaty of its own. It remains bound by the 1973 U.S.-U.S.S.R. Income Tax Convention as a successor state, as confirmed by the IRS Tajikistan country page ("Tajikistan is one of the former Soviet Republics... now covered by the treaty with the Commonwealth of Independent States (CIS), formerly known as the USSR") and IRS Pub 901 (Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan still covered). The treaty is in force as of 2026-05-31 — no suspension/termination notice for Tajikistan on the IRS A-to-Z page (last reviewed 2026-01-03); only Belarus has a partial suspension (Article III(1)(g) trade-finance interest, effective 2024-12-17), Hungary terminated (2024-01-08), and Russia partially suspended (2022). Practitioner caution: the 1973 treaty is unusually narrow — the headline 0% interest rate is restricted to trade-finance interest only; portfolio interest, bank deposit interest, etc., fall back to 30% U.S. statutory withholding. Dividends get no relief (still 30%). Royalties get a broad 0% across all categories under Article III(1)(a). Source PDF (tax-treaty-table-1.pdf) inspected directly; the "Comm. of Independent States" row literally reads: Interest 0n / Dividends 30/30 / Royalties 0/0/0/0/0.	n/a	n/a	n/a	n/a	1973 USSR treaty does not have a modern OECD-style "Business Profits / Permanent Establishment" article. It is a limited-scope, pre-model treaty primarily covering reciprocal exemptions for trade-related income, transportation, and personal services. For most active business income earned by a Tajikistan resident in the U.S., default U.S. effectively-connected-income rules apply.	[IRS]
US-Thailand income tax treaty signed 1996 is IN FORCE as of 2026-05-31. Thailand appears on IRS A-Z treaty list with no suspension/termination note (unlike Belarus, Hungary, Russia). Thailand row verified in IRS Tax Treaty Table 1 (Rev. May 2023): Interest 15% [11(2)], Dividends General 15% / Direct 10% [10(2)], Royalties columns: Industrial Equipment 8%, Know-how/Other Industrial Royalties 15%, Patents 15%, Film & TV 5%, Copyrights 5% [12(2)]. IPS rules verified in IRS Pub 901 (9-2024) under 'Thailand' heading.	n/a	n/a	n/a	n/a	Taxable only if PE in US (standard OECD-model business profits article)	[IRS]
US-Trinidad and Tobago income tax treaty (signed 1970) confirmed IN FORCE as of 2026-05-31: listed without termination/suspension notice on IRS A-Z treaty page and appears in current IRS Tax Treaty Tables 1 & 2 (Rev. May 2023). Notably, this is an older treaty that does NOT reduce US withholding on dividends or general interest from the 30% statutory rate — unusual relative to most US treaties. Trinidad row in Table 1: interest 30 z (Art. 13); dividends general 30, direct 30 (Art. 12(1)); royalties know-how 15, patents 15, copyrights 0 cc (Art. 14(1)). Table 2 row 17 IPS: 183 days, no limit (foreign contractor) or $3,000 (US contractor), Art. 17.	n/a	n/a	n/a	n/a	Taxable only if attributable to a permanent establishment in the US (standard PE rule per Table 1 caution and Art. 7 of the 1970 treaty)	[IRS]
US-Tunisia Income Tax Treaty (signed 1985, technical explanation 1989) confirmed in force as of 2026-05-31 per IRS A-Z list (no caution notice). Rates verified from IRS Tax Treaty Table 1 (Rev. May 2023), Tunisia row: Interest 15% (ftn z - govt/financial-institution exemptions may apply per Art 11(2)); Dividends General 20% w / Direct 14% w (Art 10(2)); Royalties Art 12(2)-(3): Industrial Equipment 10% (ftn xx: excludes ships/aircraft/containers in international traffic), Know-how/Other Industrial 15%, Patents 15%, Film & TV 15%, Copyrights 15%. Table 2 (Tunisia, Art 14) confirms IPS exemption with 183-day presence and $7,500 p.a. compensation cap. Pensions 0% under Art 18(1). Adversarial check: all rates appear directly in fetched IRS Table 1 PDF (line 102) and Table 2 PDF (line 629-635).	n/a	n/a	n/a	n/a	Taxable in US only if attributable to a US permanent establishment (Article 7-style, OECD model). No PE = no US tax.	[IRS]
US-Türkiye income tax treaty (signed 1996) is IN FORCE as of 2026-05-31; appears on the IRS A-to-Z list with no suspension/termination notes. Rates extracted from IRS Tax Treaty Table 1 (Rev. May 2023): Interest 15% (ftn g, z, jj — reduced/exempt rates may apply for government-paid interest, bank/financial institution interest, and commercial-credit interest per the interest article); Dividends 20% portfolio / 15% direct (ftn w applies to REIT/RIC; direct rate requires the required ownership of voting stock); Royalties split by category — industrial equipment 5%, know-how/other industrial 10%, patents 10%, film & TV 10%, copyrights 10% (ftn tt: copyright rate applies to computer software unless otherwise specified). Independent personal services and business profits are governed by Articles 14/7 of the treaty (OECD-model): exempt from US tax unless attributable to a fixed base or permanent establishment in the US. Adversarial verification: Türkiye (TU) row confirmed present on pages 3 and 5 of the IRS PDF with the exact rates cited above.	n/a	n/a	n/a	n/a	Taxable only if attributable to a permanent establishment in the US (OECD-model)	[IRS]
Turkmenistan has no separate bilateral treaty with the US. The 1973 US-USSR Income Tax Treaty remains in force for Turkmenistan via the CIS framework (per IRS Pub 901 and Turkmenistan country page). IRS A-Z list (last updated Jan 3, 2026) shows no caution/suspension/termination notice for Turkmenistan, confirming in-force status as of 2026-05-31. Verbatim from IRS Tax Treaty Table 1: row "Comm. of Independent States*" shows Interest 0n / Dividends General 30 / Direct 30 / Royalties (all columns) 0; Table 1 footnote 110-111 lists Turkmenistan among CIS countries to which the US-USSR treaty still applies. Table 2 confirms IPS exemption for ≤183 days under Article VI(2). Notable: this is one of the few US treaties where dividends get NO reduction (stays at statutory 30%).	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (1973 US-USSR treaty, Article III)	[IRS]
US-Ukraine income tax treaty signed 1994, in force since 2000 (withholding provisions effective Jan 1, 2001). Treaty is in force as of 2026-05-31 - IRS A-to-Z treaty page lists Ukraine with no suspension/termination caution (contrast: Russia "Treaty Partially Suspended", Hungary "Treaty Terminated", USSR treaty "Partially Suspended for Belarus"). Ukraine row in Table 1 (Rev. May 2023): Interest 0% [footnote g - REMIC excess inclusion carveout, Art 11(1)]; Dividends column 6 = 15% [footnote ff - RIC; REIT dividends at 30%], column 7 = 5% [direct dividend rate, Art 10(2)]; Royalties all categories = 10% [Art 12(2)], Industrial Equipment = n/a u (leasing falls under Business Profits article). Pensions 0% [Art 19(2)].	n/a	n/a	n/a	n/a	Taxable in US only if attributable to a US permanent establishment (OECD-model); otherwise exempt from US tax	[IRS]
US-UK Income Tax Treaty (2001), in force since March 31, 2003. UK is listed on IRS A-Z page without any termination/suspension caution. Table 1 (Rev. May 2023) UK row confirms: Interest paid by US obligors=0 (Art 11(1)); Dividends general=15, qualifying direct=5 (Art 10(2)); Royalties: industrial equipment n/a, know-how/other=0, patents=0, film & TV=0, copyrights=0 (Art 12(1)). Table 2 shows Independent Personal Services treated under Article 7 (Business Profits). Direct dividend rate 5% generally requires 10%+ voting stock ownership; treaty also provides 0% direct dividend rate for 80%+ ownership in certain cases (footnotes aaa/oo). Pensions 0% (Art 17(1)).	n/a	n/a	n/a	n/a	Taxable only if PE in US (Article 7, OECD-model)	[IRS]
Uzbekistan has no separate bilateral US treaty. It remains bound by the 1973 US-USSR Income Tax Treaty (applied to CIS members per IRS Pub 901 and Table 1 footnote *). Treaty confirmed IN-FORCE as of 2026-05-31 on IRS A-Z page. Key caveat: dividends get NO treaty reduction (30% both tiers, no direct dividend rate exists). Interest 0% rate (Article III(1)(g)) is LIMITED to credits/loans financing US-CIS trade per Table 1 footnote n; non-trade interest defaults to 30%. Royalties 0% across all categories (Article III(1)(a)). Independent personal services exempt up to 183 days under Article VI(2).	n/a	n/a	n/a	n/a	Taxable only if PE in US (1973 USSR/CIS treaty, OECD-model PE rule)	[IRS]
US-Venezuela income tax treaty signed 1999, in force since 2000. Verified IN-FORCE as of 2026-05-31: appears in IRS A-Z list and current Table 1 (Rev. May 2023) without any termination/suspension notice (unlike Russia, Hungary, Belarus). Treaty Article Citations from Table 1: Interest 11(2), Dividends 10(2), Royalties 12(2). Venezuela row footnote 'll' confirms 4.95% interest rate for financial institutions. Royalty subcategories: Industrial Equipment 5, Know-How/Other Industrial 10, Patents 10, Film & TV 10, Copyrights 10.	n/a	n/a	n/a	n/a	Taxable only if attributable to a US permanent establishment (OECD-model, Article 7)	[IRS]

/ 04 · What is NOT in the table

Countries without a US tax treaty pay the full 30 percent.

The matrix above only lists countries that have an income tax treaty in force with the United States. A handful of large contractor-source countries do not appear, and the default 30 percent applies on every US-source FDAP payment to a resident of those countries. IRS Publication 901 opens by reproducing the no-treaty rule under IRC 1441(a): residents of countries without an income tax treaty with the United States are subject to 30 percent withholding on US-source FDAP unless the income is effectively connected with a US trade or business.

The countries that come up most often in contractor work and have no comprehensive US income tax treaty include Singapore, Vietnam, Argentina, Hong Kong, the United Arab Emirates, Saudi Arabia, Brazil (no comprehensive bilateral income tax treaty as of the verification date), Chile (treaty signed but not in force for the full set of articles), Colombia, Peru, Taiwan, and most of sub-Saharan Africa outside of South Africa. The current in-force-status list lives on the IRS US Income Tax Treaties A-Z page, which the matrix is verified against on the date noted in the hero.

A W-8BEN from a no-treaty resident still has to be collected. It documents the payee as foreign and supports the 30 percent withholding decision under 26 CFR 1.1441-1(b)(1). Without the W-8 the same 30 percent applies under the presumption rules, but the agent loses the ability to defend the classification of the payee.

/ 05 · How to claim a treaty rate (payer steps)

Six steps every US payer runs before applying a reduced rate.

Confirm the payee is a resident of a treaty country. Residency is determined under the treaty's residence article, not citizenship or mailing address. The W-8BEN line 9 asks the payee to state the country of residence for treaty purposes. About Form W-8BEN.
Identify the right income article in the treaty. Dividends, interest, royalties, and services each have separate articles with separate rates. Read the actual treaty text on the IRS page linked from the source column above, not a summary, when the payment value is meaningful. IRS US Income Tax Treaties A-Z.
Collect the W-8BEN (individual) or W-8BEN-E (entity) with Part II completed. Part II is the treaty claim section. It has to identify the country of residence, the article, the paragraph, the income type, and the reduced rate. A W-8 missing Part II does not support a treaty rate even if the payee is obviously eligible. About Form W-8BEN-E.
Withhold at the treaty rate on the gross payment. The treaty rate replaces the 30 percent default. Withhold the reduced rate on the full gross amount, not the net. IRS NRA Withholding.
Deposit the withheld tax on the Treasury schedule. Monthly or semi-weekly based on the running undeposited balance. Treaty rate or default rate, the deposit obligation is the same. 26 CFR 1.6302-2.
Report the rate and exemption code on Form 1042-S. Box 3a is the chapter 3 exemption code, Box 3b is the chapter 3 tax rate. The 1042-S instructions list the exemption codes for treaty claims. About Form 1042.

/ 06 · Common mistakes

Where US AP teams trip on treaty claims.

Applying a treaty rate without a W-8BEN Part II claim. The treaty rate is not self-executing. A W-8BEN without Part II completed does not support the reduced rate even if the payee is plainly a resident of a treaty country. The presumption rules in 26 CFR 1.1441-1(b)(1) send the payment back to 30 percent.
Confusing the direct-dividend and portfolio-dividend rates. Most US treaties have two dividend rates. The lower rate (often 5 percent) only applies to a corporate shareholder owning a meaningful percentage of the payer's voting stock. The portfolio rate (often 15 percent) applies to all other dividends. The matrix on this page shows the portfolio rate. Confirm the direct-dividend rate against the actual article text in Publication 901 for the specific country.
Treating a no-treaty country as zero rate. No treaty means the 30 percent default under IRC 1441(a) applies on the full gross payment. A W-8BEN from the payee does not change the rate. It only documents the payee as foreign.
Missing the limitation-on-benefits article. Many modern US treaties have a limitation on benefits (LOB) article that restricts treaty benefits to qualified persons. W-8BEN-E Part III asks the entity to identify which LOB test it satisfies. A W-8BEN-E that leaves the LOB box blank does not support the treaty claim under the IRS form instructions. About Form W-8BEN-E.
Forgetting to refresh the W-8 before it expires. A W-8BEN is generally valid for three calendar years after the year it is signed unless a change in circumstances breaks it sooner. Publication 515 sets the validity period. An expired W-8 is no W-8, and the next payment defaults to 30 percent under the presumption rules.

/ 07 · What this connects to

Where to go next.

The hub and the rest of the US payer pillar set.

/ 08 · Tools

Free tooling for US payer compliance.

/ 09 · Questions

Frequently asked.

01 How does a treaty rate work? +

A US income tax treaty assigns a maximum US withholding rate to specific income types paid to residents of the treaty partner country. The default chapter 3 rate under IRC 1441(a) is 30 percent on US-source FDAP. A treaty article on dividends, interest, royalties, or services overrides that default and sets a lower cap, often 0, 5, 10, or 15 percent. The reduced rate only applies when the foreign recipient delivers a valid Form W-8BEN (individual) or W-8BEN-E (entity) that claims the treaty benefit and identifies the article and rate. Without the W-8, the 26 CFR 1.1441-1(b)(1) presumption rules push the payment back to 30 percent regardless of what the treaty says.

02 Does every payment to a foreign person qualify for a treaty rate? +

No. A treaty only reduces withholding on income types the treaty article covers. Dividends, interest, royalties, and certain services are the common categories. Personal services income often has its own article with its own conditions, such as a day-count test or a fixed-base test. Some treaties have a limitation on benefits article that narrows the population of eligible residents. Income that is foreign-source is outside chapter 3 entirely and never needs a treaty. Income that is effectively connected with a US trade or business moves to net-basis taxation on Form 1040-NR or 1120-F, not the chapter 3 treaty rate. The starting point is always the income article in the actual treaty text, which the IRS publishes on its US Income Tax Treaties A-Z page.

03 What is portfolio dividend vs direct dividend? +

Most US treaties split the dividend article into two rates. The lower rate (often 5 percent) applies to a direct dividend, which is a dividend paid to a corporate shareholder that owns a meaningful percentage of the voting stock of the payer (often 10 percent or more). The higher rate (often 15 percent) is the portfolio rate that applies to all other dividends, including those paid to individual shareholders and to small corporate holders. The matrix on this page reports the rate the IRS lists in Publication 901 for the standard portfolio dividend column. Confirm the direct-dividend rate against the treaty text for the specific country before applying it.

04 Why do some treaty rates show ranges? +

Some treaty articles set different rates within the same income category depending on the underlying facts. Royalties is the most common example because most treaties split royalties into industrial royalties, copyright royalties, and film royalties, each with a different cap. Interest is sometimes split between bank interest and other interest. When the matrix shows a range like 0 to 10 percent, the row covers all subcategories in that treaty article. The payer has to read the article in the actual treaty text to pick the rate that fits the specific payment.

05 What happens if there is no treaty? +

The default 30 percent under IRC 1441(a) and 26 CFR 1.1441-1(b)(1) applies on the full gross payment of US-source FDAP. IRS Publication 901 reproduces the no-treaty rule in its opening pages: residents of countries that do not have an income tax treaty with the United States are subject to the statutory 30 percent rate on US-source FDAP unless the income is effectively connected with a US trade or business, in which case the foreign payee files a US net-basis return. Common no-treaty countries that come up in contractor work include Singapore, Vietnam, Argentina, Brazil (limited treaty coverage), and several Gulf jurisdictions. A W-8BEN from a no-treaty resident does not reduce the rate. The agent still has to collect the form so that the payee is documented as foreign.

06 How often do these rates change? +

Slowly. Treaty rates change when the United States and the partner country sign a new treaty or a protocol amending an existing one, and the change only takes effect after both legislatures ratify and the instruments of ratification are exchanged. That is a multi-year process. The IRS reflects the new rates in Publication 901 and the US Income Tax Treaties A-Z page after the protocol enters into force. The matrix on this page is verified against those two sources as of 2026-05-31. Re-verify before applying any rate on a high-value payment.

07 Can a foreign payee claim a treaty rate without a US TIN on the W-8BEN? +

Sometimes. The Form W-8BEN and W-8BEN-E instructions allow a foreign tax identification number (FTIN) issued by the payee's country of residence in lieu of a US TIN for most income types, with a narrow set of exceptions where a US TIN is still required (for example, certain treaty claims on dividends paid by REITs and a few other categories). The default position the payer should take is that an FTIN is acceptable for most contractor and royalty payments. Confirm against the current W-8BEN or W-8BEN-E instructions on the IRS forms page before relying on this for any specific payment.

08 Does the payer have to file a separate IRS form to apply a treaty rate? +

No special IRS form. The treaty rate is applied at the time of payment based on the W-8BEN or W-8BEN-E on file. The agent reports the reduced rate, the income code, the exemption code, and the treaty country on Form 1042-S at year-end, and the totals roll up onto Form 1042. The W-8 stays in the agent's records as the support for the rate that was applied. IRS NRA Withholding and the Form 1042-S instructions cover the reporting codes.

This guide is general information for US withholding agents, not legal or tax advice. Treaty rates listed in the matrix are reduced caps from the relevant income article of the US treaty as published by the IRS in Publication 901 and on the US Income Tax Treaties A-Z page. The rate that applies to any specific payment depends on the payee's residency, the income type, the article subcategory, the limitation-on-benefits article, and whether a valid W-8BEN or W-8BEN-E is on file at the time of payment, and any of those can change. Confirm every position against the current Publication 901, the actual treaty text, and the W-8 instructions linked above, or work with a qualified US tax professional. Omnivoo does not act as the withholding agent on your contractor payments and the responsibility for Form W-8 collection, withholding at the treaty rate, Treasury deposits, Form 1042 and 1042-S filing, and recipient-copy furnishing remains with the US payer.