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IRS.gov Website
Publication 515
taxmap/pubs/p515-011.htm#en_us_publink1000225127

Tax Treaty Tables(p37)

rule
The United States has income tax treaties (or conventions) with a number of foreign countries under which residents (sometimes limited to citizens) of those countries are taxed at a reduced rate or are exempt from U.S. income taxes on certain income received from within the United States.
Income that is exempt under a treaty is not subject to withholding at source under the statutory rules discussed in this publication.
taxmap/pubs/p515-011.htm#en_us_publink1000225128

Three tables follow:(p37)

rule
taxmap/pubs/p515-011.htm#en_us_publink1000225129
Table 1(p37)
lists the withholding rates on income other than personal service income.
taxmap/pubs/p515-011.htm#en_us_publink1000225130
Table 2(p37)
lists the different types of personal service income that are entitled to an exemption from, or reduction in, withholding.
taxmap/pubs/p515-011.htm#en_us_publink1000225131
Table 3(p37)
shows where the full text of each treaty and protocol may be found in the Cumulative Bulletins if it has been published.
EIC
These tables are not meant to be a complete guide to all provisions of every income tax treaty. For detailed information, you must consult the provisions of the tax treaty that apply to the country of the nonresident alien to whom you are making payment.
You can obtain the full text of these treaties at IRS.gov.

Table 1. Withholding Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties—For Withholding in 2011

Income Code Number 123679
  InterestDividends 
NameCodePaid by U.S. Obligors— GeneralddOn Real Property MortgagesddPaid to a Controlling Foreign CorporationddPaid by U.S. Corporations—Generala,ddQualifying for Direct Dividend Ratea,ddCapital Gainse,u,dd
AustraliaAS10 g,k,nn10 g,k,ee,nn10 g,k,nn15 g,mm 5 g,mm,oo30
AustriaAU 0 g,jj 0 g,ee,jj 0 g,jj15 g,w 5 g,w 0 g
BangladeshBG10 g,bb,jj10 g,bb,ee,jj10 g,bb,jj15 g,mm10 b,g,mm 0 g
BarbadosBB 5 g 5 g 5 g15 g,w 5 b,g,w 0 g
BelgiumBE 0 g,jj 0 g,ee,jj 0 g,jj15 g,ss,tt 5 g,oo,ss,tt 0 g
BulgariaBU 5 g,jj,nn,ss 5 g,ee,jj,nn,ss 5 g,jj,nn,ss10 g,ss,tt 5 g,ss,tt 0 g
CanadaCA 0 g,jj 0 g,ee,jj 0 g,jj15 g,mm 5 g,mm 0 r
China, People's Rep. ofCH10 g10 g10 g10 g10 g30
Comm. of Independent States* 0 n30303030 0 o
CyprusCY10 g10 g10 g15 g 5 b,g 0 g
Czech RepublicEZ 0 g 0 g,ee 0 g15 g,w 5 b,g,w 0 g
DenmarkDA 0 g,kk 0 g,ee,kk 0 g,kk15 g,ss,tt 5 g,oo,ss,tt 0 g
EgyptEG15 h3015 h15 h 5 b,h 0 h
EstoniaEN10 g,kk10 g,ee,kk10 g,kk15 g,w 5 b,g,w 0 g
FinlandFI 0 g,kk 0 g,ee,kk 0 g,kk15 g,ss,tt 5 g,oo,ss,tt 0 g
FranceFR 0 g 0 g,ee 0 g15 g,tt 5 g,oo,tt 0 g
GermanyGM 0 g,jj 0 g,ee,jj 0 g,jj15 g,ss,tt 5 g,oo,ss,tt 0 g
GreeceGR 0 h 0 h30303030
HungaryHU 0 g 0 g 0 g15 g 5 b,g 0 g
IcelandIC 0 g,kk 0 g,ee,kk 0 g,kk15 g,mm,ss 5 g,mm,ss 0 g
IndiaIN15 g,z15 g,z15 g,z25 g,w15 b,g,w30
IndonesiaID10 g10 g10 g15 g10 b,g 0 g
IrelandEI 0 g 0 g,ee 0 g15 g,mm 5 g,mm 0 g
IsraelIS171/2 z,gg 171/2 z,ee,gg 171/2 z,gg 25 w,gg121/2 b,w,gg  0 gg
ItalyIT10 g,yy10 g,ee,yy10 g,yy15 g,mm 5 g,mm 0 g
JamaicaJM121/2 g 121/2 g 121/2 g 15 g10 b,g 0 g
JapanJA10 g,qq,rr,ss10 g,ee,qq,rr,ss 10 g,qq,rr,ss10 g,qq,ss,tt  5 b,g,qq,ss,tt 0 g
KazakhstanKZ10 g10 g,ee10 g15 g,ff 5 b,g,ff 0 g
Korea, SouthKS12 g12 g12 g15 g10 b,g 0 g
LatviaLG10 g,kk10 g,ee,kk10 g,kk15 g,w 5 b,g,w 0 g
LithuaniaLH10 g,kk10 g,ee,kk10 g,kk15 g,w 5 b,g,w 0 g
LuxembourgLU 0 g,k 0 g,ee,k 0 g,k15 g,w 5 b,g,w 0 g
 * Those countries to which the U.S.-U.S.S.R. income tax treaty still applies: Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan.

Table 1.Withholding Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties—For Withholding in 2011

Income Code Number 1011121314
   Royalties 
NameCodeEquipmentKnow-howFilm & TVCopyrightsPatentsReal Property Income and Natural ResourceszzPensions and Annuities
AustraliaAS30 u 5 g 5 g 5 g 5 g30 0 d
AustriaAU30 u 0 g10 g 0 g 0 g30 0
BangladeshBG30 u10 g10 g10 g10 g30 0 d,f,q
BarbadosBB30 u 5 g 5 g 5 g 5 g30 0 d,f
BelgiumBE30 u 0 g 0 g 0 g 0 g30 0 d,f
BulgariaBU30 u 5 g 5 g 5 g 5 g30 0 d,f
CanadaCA30 u 0 g10 g 0 g 0 g3015
China, People's Rep. ofCH10 g,v10 g10 g10 g10 g30 0 d,t
Comm. of Independent States 0 0 0 0 03030
CyprusCY30 u 0 g 0 g 0 g 0 g30 0 d,f
Czech RepublicEZ10 g10 g 0 g 0 g10 g30 0 d,f
DenmarkDA30 u 0 g 0 g 0 g 0 g3030 c,d,t
EgyptEG30 u30 u30 u15 g15 g30 0 d,f
EstoniaEN 5 g10 g10 g10 g10 g30 0 d,f
FinlandFI 30 u 0 g 0 g 0 g 0 g30 0 d,f
FranceFR30 u 0 g 0 g 0 g 0 g30 30
GermanyGM30 u 0 g30 0 g 0 g30 0 d,f
GreeceGR 0 h30 u30 u 0 h 0 h30 0 d
HungaryHU30 u 0 g 0 g 0 g 0 g30 0 d,f
IcelandIC30 u 5 g 5 g 0 g,I 0 g30 0 d
IndiaIN10 g15 g15 g15 g15 g30 0 d,f
IndonesiaID10 g10 g10 g10 g10 g3015 d,f,q
IrelandEI30 u 0 g 0 g 0 g 0 g30 0 d,f
IsraelIS30 u, gg30 u, gg10 gg10 gg15 gg30 0 f
ItalyIT 5 g 8 g 8 g 0 g 8 g30 0 d,f
JamaicaJM30 u10 g10 g10 g10 g30 0 d,f,p
JapanJA30 u 0 g,qq 0 g,qq 0 g,qq 0 g,qq30 0 d
KazakhstanKZ10 g10 g10 g10 g10 g30 0 d,f
Korea, SouthKS30 u15 g10 g10 g15 g30 0 d,f
LatviaLG 5 g10 g10 g10 g10 g30 0 d,f
LithuaniaLH 5 g10 g10 g10 g10 g30 0 d,f
LuxembourgLU30 u 0 g 0 g 0 g 0 g30 0 d

Table 1.Withholding Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties—For Withholding in 2011

Income Code Number 123679
  InterestDividends 
NameCodePaid by U.S. Obligors— GeneralddOn Real Property MortgagesddPaid to a Controlling Foreign CorporationddPaid by U.S. Corporations—Generala,ddQualifying for Direct Dividend Ratea,ddCapital Gainse,u,dd
MaltaMT10 g,jj10 g,ee,jj10 g,jj15 g,tt 5 g,tt 0 g
MexicoMX15 g,hh15 g,ee,hh15 g10 g,mm,pp 5 g,mm,oo,pp 0 g
MoroccoMO15 g15 g15 g15 g10 b,g 0 g
NetherlandsNL 0 g 0 g 0 g15 g,xx 5 b,gg,oo,xx 0
New ZealandNZ10 g,jj,nn10 g,ee,jj,nn10 g,jj,nn15 g,tt 5 g,tt 0 g
NorwayNO 0 g 0 g 0 g15 g15 g 0 g
PakistanPK3030303015 b,h30
PhilippinesRP15 g15 g15 g25 g20 b,g 0 g
PolandPL 0 g 0 g 0 g15 g 5 b,g 0 g
PortugalPO10 h10 h,ee10 h15 h,w 5 b,h,w 0 g
RomaniaRO10 g10 g10 g10 g10 g 0 g
RussiaRS 0 g 0 g,ee 0 g10 g,ff 5 b,g,w 0 g
Slovak RepublicLO 0 g 0 g,ee 0 g15 g,w 5 b,g,mm 0 g
SloveniaSI 5 g 5 g,ee 5 g15 g,mm 5 b,g,mm 0 g
South AfricaSF 0 g,jj 0 g,ee,jj 0 g,jj15 g,w 5 g,w 0
SpainSP10 g10 g10 g15 g,w10 b,g,w 0 g
Sri LankaCE10 g,jj10 g,ee,jj10 g,jj15 g,ww15 g,ww 0 g,uu
SwedenSW 0 g 0 g,ee 0 g15 g,ss,tt 5 b,g,oo,ss,tt 0 g
SwitzerlandSZ 0 g,y 0 g,y,ee 0 g,y15 g,w 5 g,w 0
ThailandTH15 g,z15 g,z,ee15 g,z15 g,w10 g,w30
Trinidad & TobagoTD303030303030
TunisiaTS15 g15 g15 g20 g,w14 b,g,w 0 g
TurkeyTU15 g,m,z15 g,m,z,ee15 g,m,z20 g,w15 g,w 0 g
UkraineUP 0 g 0 g,ee 0 g15 g,ff 5 b,g,ff 0 g
United KingdomUK 0 g,kk,qq 0 g,ee,kk,qq 0 g,kk,qq15 g,mm,qq 5 g,mm,oo,qq 0 g
VenezuelaVE10 g,kk,ll10 g,ee,kk,ll10 g,kk,ll15 g,mm 5 b,g,mm 0 g
Other Countries 303030303030

Table 1. Withholding Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties—For Withholding in 2011

Income Code Number 1011121314
   Royalties 
NameCodeEquipmentKnow-howFilm & TVCopyrightsPatentsReal Property Income and Natural Resources zzPensions and Annuities
MaltaMT30 u10 g10 g10 g10 g30 0 d,f
MexicoMX10 g10 g10 g10 g10 g30 0 d
MoroccoMO30 u10 g10 g10 g10 g30 0 d,f
NetherlandsNL30 u 0 g30 g 0 g 0 g30 0 d,f,ii
New ZealandNZ30 u 5 g 5 g 5 g 5 g30 0 d
NorwayNO30 u 0 g30 u 0 g 0 g30 0 d,f
PakistanPK30 u30 u30 u 0 g 0 g30 0 d,j
PhilippinesRP30 u15 g15 g15 g15 g3030 q
PolandPL30 u10 g10 g10 g10 g3030
PortugalPO10 h10 h10 h10 h10 h30 0 d,f
RomaniaRO30 u15 g10 g10 g15 g30 0 d,f
RussiaRS30 u 0 g 0 g 0 g 0 g30 0 d
Slovak RepublicLO10 g10 g 0 g 0 g10 g30 0 d,f
SloveniaSI30 u 5 g 5 g 5 g 5 g30 0 d,f
South AfricaSF30 u 0 g 0 g 0 g 0 g3015 d,l
SpainSP 8 g,aa10 g,aa 8 g,aa 5 g,aa10 g,aa30 0 d,f
Sri LankaCE 5 g10 g10 g10 g10 g30 0 d,t
SwedenSW30 u 0 g 0 g 0 g 0 g30 0 d
SwitzerlandSZ30 u 0 g30 g,u 0 g 0 g30 0 d
ThailandTH 8 g15 g 5 g 5 g15 g30 0 d,f
Trinidad & TobagoTD30 u15 g30 u 0 g,cc1530 0 d,f
TunisiaTS10 g15 g15 g15 g15 g30 0 f
TurkeyTU 5 g10 g10 g10 g10 g30 0 d
UkraineUP30 u10 g10 g10 g10 g30 0 d
United KingdomUK30 u 0 g,qq 0 g,qq 0 g,qq 0 g,qq30 0 d,f
VenezuelaVE 5 g10 g10 g10 g10 g30 0 d,t
Other Countries 30303030303030
aNo U.S. tax is imposed on a percentage of any dividend paid by a U.S. corporation that received at least 80% of its gross income from an active foreign business for the 3-year period before the dividend is declared. (see sections 871(i)(2)(B) and 881(d) of the Internal Revenue Code.
bThe reduced rate applies to dividends paid by a subsidiary to a foreign parent corporation that has the required percentage of stock ownership. In some cases, the income of the subsidiary must meet certain requirements (e.g., a certain percentage of its total income must consist of income other than dividends and interest). For Japan, dividends received from a more than 50% owned corporate subsidiary are exempt if certain conditions are met.
cGenerally, if the person was receiving pension distributions before March 31, 2000, the distributions continue to be exempt from U.S. tax.
dExemption does not apply to U.S. Government (federal, state, or local) pensions and annuities; a 30% rate applies to these pensions and annuities. For this purpose, railroad retirement tier 2, dual, and supplemental benefits are not considered U.S. Government pensions or annuities. U.S. Government pensions paid to an individual who is both a resident and national of Bangladesh, Belgium, Bulgaria, China, Denmark, Estonia, Finland, Germany, Hungary, Iceland, India, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Mexico, the Netherlands, Portugal, Russia, Slovenia, South Africa, Spain, Switzerland, Thailand, Turkey, the United Kingdom, or Venezuela are exempt from U.S. tax. U.S. Government pensions paid to an individual who is both a resident and citizen of Kazakhstan, New Zealand, or Sweden are exempt from U.S. tax.
eNo withholding is required on capital gains other than those listed earlier under Capital Gains, even if the gain is subject to U.S. tax.
fIncludes alimony.
gThe exemption or reduction in rate does not apply if the recipient has a permanent establishment in the United States and the property giving rise to the income is effectively connected with this permanent establishment. Under certain treaties, exemption or reduction in rate also does not apply if the property producing the income is effectively connected with a fixed base in the United States from which the recipient performs independent personal services. Even with the treaty, if the income is not effectively connected with a trade or business in the United States by the recipient, the recipient will be considered as not having a permanent establishment in the United States under Internal Revenue Code section 894(b).
hThe exemption or reduction in rate does not apply if the recipient is engaged in a trade or business in the United States through a permanent establishment that is in the United States. However, if the income is not effectively connected with a trade or business in the United States by the recipient, the recipient will be considered as not having a permanent establishment in the United States to apply the reduced treaty rate to that item of income.
iThe rate is 5% for trademarks and any information for rentals of industrial, commercial, or scientific equipment.
jExemption is not available when paid from a fund under an employees' pension or annuity plan, if contributions to it are deductible under U.S. tax laws in determining taxable income of the employer.
kThe rate is 15% for interest determined with reference to the profits of the issuer or one of its associated enterprises.
lAnnuities purchased while the annuitant was not a resident of the United States are not taxable. The reduced rate applies if the distribution is not subject to a penalty for early withdrawal.
mContingent interest that does not qualify as portfolio interest is treated as a dividend and is subject to the rate under column 6 or 7.
nThe 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.
oThe exemption applies only to gains from the sale or other disposition of property acquired by gift or inheritance.
pThe exemption does not apply if the recipient was a resident of the United States when the pension was earned or when the annuity was purchased.
qAnnuities paid in return for other than the recipient's services are exempt. For Bangladesh, exemption does not apply to annuity received for services rendered.
rGenerally, if the property was owned by the Canadian resident on September 26, 1980, not as part of the business property of a permanent establishment or fixed base in the U.S., the taxable gain is limited to the appreciation after 1984. Capital gains on personal property not belonging to a permanent establishment or fixed base of the taxpayer in the U.S. are exempt.
sThe rate for royalties with respect to tangible personal property is 7%.
tDoes not apply to annuities. For Denmark, annuities are exempt.
uDepending on the facts, the rate may be determined by either the Business Profits article or the Other Income article.
vTax imposed on 70% of gross royalties for rentals of industrial, commercial, or scientific equipment.
wThe rate in column 6 applies to dividends paid by a regulated investment company (RIC) or a real estate investment trust (REIT). However, that rate applies to dividends paid by a REIT only if the beneficial owner of the dividends is an individual holding less than a 10% interest (25% in the case of Portugal, Spain, and Tunisia) in the REIT.
xRoyalties not taxed at the 5% or 8% rate are taxed at a 10% rate, unless footnote (g) applies.
yThe exemption does not apply to contingent interest that does not qualify as portfolio interest. Generally, this is interest based on receipts, sales, income, or changes in the value of property.
zThe rate is 10% if the interest is paid on a loan granted by a bank or similar financial institution. For Thailand, the 10% rate also applies to interest from an arm's length sale on credit of equipment, merchandise, or services.
aaThe rate is 8% for copyrights of scientific work.
bbThe rate is 5% for interest (a) beneficially owned by a bank or other financial institution (including an insurance company) or (b) paid due to a sale on credit of any industrial, commercial, or scientific equipment, or of any merchandise to an enterprise.
ccThe rate is 15% for copyrights of scientific work.
ddUnder some treaties, the reduced rates of withholding may not apply to a foreign corporation unless a minimum percentage of its owners are citizens or residents of the United States or the treaty country.
eeExemption or reduced rate does not apply to an excess inclusion for a residual interest in a real estate mortgage investment conduit (REMIC).
ffThe rate in column 6 applies to dividends paid by a regulated investment company (RIC). Dividends paid by a real estate investment trust (REIT) are subject to a 30% rate.
ggThe exemption or reduction in rate does not apply if the recipient has a permanent establishment in the United States and the income is effectively connected with this permanent establishment. Instead, tax is not withheld at source and the provisions of Article 8 (Business profits) apply. Additionally, even if the income is not effectively connected with a U.S. permanent establishment, the recipient may choose to treat net interest income as industrial or commercial profits subject to Article 8 of the treaty.
hhThe rate is 4.9% for interest derived from (1) loans granted by banks and insurance companies and (2) bonds or securities that are regularly and substantially traded on a recognized securities market. The rate is 10% for interest not described in the preceding sentence and paid (i) by banks or (ii) by the buyer of machinery and equipment to the seller due to a sale on credit.
iiThe exemption does not apply if (1) the recipient was a U.S. resident during the 5-year period before the date of payment, (2) the amount was paid for employment performed in the United States, and (3) the amount is not a periodic payment, or is a lump-sum payment in lieu of a right to receive an annuity.
jjThe rate is 15% (10% for Bulgaria; 30% for Germany and Switzerland) for contingent interest that does not qualify as portfolio interest. Generally, this is interest based on receipts, sales, income, or changes in the value of property.
kkThe rate is 15% for interest determined with reference to (a) receipts, sales, income, profits or other cash flow of the debtor or a related person, (b) any change in the value of any property of the debtor or a related person, or (c) any dividend, partnership distribution, or similar payment made by the debtor or related person.
llThe rate is 4.95% if the interest is beneficially owned by a financial institution (including an insurance company).
mmThe rate in column 6 applies to dividends paid by a regulated investment company (RIC) or real estate investment trust (REIT). However, that rate applies to dividends paid by a REIT only if the beneficial owner of the dividends is (a) an individual (or pension fund, in the case of France) holding not more than a 10% interest in the REIT, (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified.
nnInterest received by a financial institution is exempt.
ooDividends received from an 80%-owned corporate subsidiary are exempt if certain conditions are met.
ppDividends received by a trust, company, or other organization operated exclusively to administer or provide pension, retirement, or other employee benefits generally are exempt if certain conditions are met.
qqExemption does not apply to amount paid under, or as part of, a conduit arrangement.
rrInterest is exempt if (a) paid to certain financial institutions, or (b) paid on indebtedness from the sale on credit of equipment or merchandise.
ssAmounts paid to a pension fund that are not derived from the carrying on of a business, directly or indirectly, by the fund are exempt. This includes amounts paid by a REIT only if the conditions in footnote tt are met. For Sweden, to be entitled to the exemption, the pension fund must not sell or make a contract to sell the holding from which the dividend is derived within 2 months of the date the pension fund acquired the holding.
ttThe rate in column 6 applies to dividends paid by a regulated investment company (RIC) or real estate investment trust (REIT). However, that rate applies to dividends paid by a REIT only if the beneficial owner of the dividends is (a) an individual or pension fund holding not more than a 10% interest in the REIT, (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified. Dividends paid to a pension fund from a RIC, or a REIT that meets the above conditions, are exempt. For Sweden, the pension fund must also satisfy the requirements in footnote ss.
uuThe exemption does not apply to a sale of a U.S. company's stock representing ownership of 50% or more.
vvThe rate is 5% for the rental of tangible personal property.
wwThe rate applies to dividends paid by a real estate investment trust (REIT) only if the beneficial owner of the dividends is (a) an individual holding less than a 10% interest in the REIT, (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified.
xxThe rate in column 6 applies to dividends paid by a regulated investment company (RIC) or real estate investment trust (REIT). However, that rate applies to dividends paid by a REIT only if the beneficial owner of the dividends is (a) an individual holding not more than a 25% interest in the REIT (b) a person holding not more than 5% of any class of the REIT's stock and the dividends are paid on stock that is publicly traded, or (c) a person holding not more than a 10% interest in the REIT and the REIT is diversified, or (d) a Dutch belegginginstelling.
yyInterest paid or accrued on the sale of goods, merchandise, or services between enterprises is exempt. Interest paid or accrued on the sale on credit of industrial, commercial, or scientific property is exempt.
zzWithholding at a special rate may be required on the disposition of U.S. real property interests. See U.S. Real Property Interest earlier in this publication.
  
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