US income tax treaties by country

Updated

The IRS lists US income tax treaties with 67 countries, and 66 of them are in effect today. Without a treaty, US-source dividends and royalties paid to a nonresident are withheld at 30%. Interest often is not: the tax code exempts most portfolio interest and ordinary bank-deposit interest outright, so a treaty rate on interest matters only for interest the code does not already exempt. A treaty caps what the paying country can take. For the 11 treaties we have read in full, the cap on dividends for an ordinary investor is 10% to 15%.

Three things the list does not make obvious. Hungary's treaty was terminated and stopped applying to US withholding on January 1, 2024, so payments that once qualified are back at 30%. Some treaties in effect carry suspensions: Belarus's covers one article of the US-USSR treaty, Article III(1)(g), scheduled to run until 2026-12-31; Russia's covers every article that sets a withholding rate. Each is explained below. And nine former Soviet states have no treaty of their own: they still use the US-USSR treaty, which IRS lists as generally effective from 1987.

What are the treaty withholding rates by country?

The rate shown is the most the paying country may withhold from an ordinary individual investor. A rate marked with an asterisk has other tiers, usually lower rates for companies with a large holding or for pension funds, and the country page lists each one with who qualifies.

Treaty withholding rates for an ordinary investor, by country
CountryDividendsInterestRoyaltiesIn force from
Australia 15%* 10%* 5% 1983
Canada 15%* 0%* 0% to 10%* 1985
France 15%* 0%* 0% 1996
Germany 15%* 0% 0% 1990
Italy 15%* 10%* 0% to 8%* 2010
Japan 10%* 0%* 0%* 2005
Mexico 10%* 15%* 10% 1994
Portugal 15%* 10%* 10%* 1996
Spain 15%* 0%* 0% 1991
Thailand 15%* 15%* 5% to 15%* 1998
United Kingdom 15%* 0%* 0% 2004

* Other rates apply to some recipients; see the country page. Read from each treaty and its protocols as linked from the IRS, and checked a second time against the same texts. "Treaty applies from" is the general effective year IRS lists for the treaty itself; later protocols changed some rates, and each country page says which document sets each rate today.

Which countries have an income tax treaty with the US?

All 67, with the year each treaty generally took effect and its current status. Countries with a page are linked; for the rest, the IRS link goes to the treaty text and protocols.

Countries with a US income tax treaty
CountryApplies fromStatusTreaty text
Armenia 1987 Uses the US-USSR treaty IRS documents
Australia 1983 In effect IRS documents
Austria 1999 In effect IRS documents
Azerbaijan 1987 Uses the US-USSR treaty IRS documents
Bangladesh 2007 In effect IRS documents
Barbados 1984 In effect IRS documents
Belarus 1987 Partly suspended IRS documents
Belgium 2008 In effect IRS documents
Bulgaria 2009 In effect IRS documents
Canada 1985 In effect IRS documents
Chile 2024 In effect IRS documents
China 1987 In effect IRS documents
Cyprus 1986 In effect IRS documents
Czech Republic 1994 In effect IRS documents
Denmark 2001 In effect IRS documents
Egypt 1982 In effect IRS documents
Estonia 2000 In effect IRS documents
Finland 1991 In effect IRS documents
France 1996 In effect IRS documents
Georgia 1987 Uses the US-USSR treaty IRS documents
Germany 1990 In effect IRS documents
Greece 1953 In effect IRS documents
Hungary 1980 Terminated (last applied 2023) IRS documents
Iceland 2009 In effect IRS documents
India 1991 In effect IRS documents
Indonesia 1990 In effect IRS documents
Ireland 1998 In effect IRS documents
Israel 1995 In effect IRS documents
Italy 2010 In effect IRS documents
Jamaica 1982 In effect IRS documents
Japan 2005 In effect IRS documents
Kazakhstan 1996 In effect IRS documents
Korea 1980 In effect IRS documents
Kyrgyzstan 1987 Uses the US-USSR treaty IRS documents
Latvia 2000 In effect IRS documents
Lithuania 2000 In effect IRS documents
Luxembourg 2001 In effect IRS documents
Malta 2011 In effect IRS documents
Mexico 1994 In effect IRS documents
Moldova 1987 Uses the US-USSR treaty IRS documents
Morocco 1981 In effect IRS documents
Netherlands 1994 In effect IRS documents
New Zealand 1984 In effect IRS documents
Norway 1971 In effect IRS documents
Pakistan 1960 In effect IRS documents
Philippines 1983 In effect IRS documents
Poland 1974 In effect IRS documents
Portugal 1996 In effect IRS documents
Romania 1974 In effect IRS documents
Russia 1994 Partly suspended IRS documents
Slovak Republic 1993 In effect IRS documents
Slovenia 2002 In effect IRS documents
South Africa 1998 In effect IRS documents
Spain 1991 In effect IRS documents
Sri Lanka 2004 In effect IRS documents
Sweden 1996 In effect IRS documents
Switzerland 1998 In effect IRS documents
Tajikistan 1987 Uses the US-USSR treaty IRS documents
Thailand 1998 In effect IRS documents
Trinidad 1970 In effect IRS documents
Tunisia 1990 In effect IRS documents
Turkey 1998 In effect IRS documents
Turkmenistan 1987 Uses the US-USSR treaty IRS documents
Ukraine 2001 In effect IRS documents
United Kingdom 2004 In effect IRS documents
Uzbekistan 1987 Uses the US-USSR treaty IRS documents
Venezuela 2000 In effect IRS documents

Source: IRS Table 3, List of Tax Treaties, updated through September 26, 2025, and the IRS treaty index. The IRS index also lists the US Model treaty, which is a template rather than a treaty with anyone, so it is not counted here.

What does a tax treaty actually change?

A US income tax treaty does three main things for a resident of the other country. It caps the tax the paying country can withhold on investment income. It settles which country you are a resident of when both would otherwise claim you, using a list of tie-breaker tests. And it assigns the right to tax pensions, Social Security and a few kinds of pay.

What it usually does not do is stop the US taxing its own citizens. Every one of the 11 treaties we have read in full has a saving clause that keeps that right, with specific exceptions that differ from treaty to treaty.

Which countries still use the old Soviet tax treaty?

Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan have no income tax treaty of their own with the US. The US-USSR treaty, which IRS lists as generally effective from 1987, still governs all 9. Other former Soviet republics, including Kazakhstan and Ukraine, have treaties of their own.

Belarus has no treaty of its own. The U.S.-U.S.S.R. income tax treaty, in force since 1987, applies (IRS Table 3, footnote 6). Operation of Article III(1)(g) is suspended by mutual agreement from 2024-12-17 until 2026-12-31 or earlier if the two governments decide.

Is the US-Hungary tax treaty still in effect?

No. Terminated. The United States notified Hungary on 2022-07-08 that it would end the 1979 treaty, and termination took effect 2023-01-08. For taxes withheld at source the treaty stopped applying on 2024-01-01, and from that date a withholding agent must withhold at the statutory 30% rate on payments that used to qualify for a treaty rate (IRS Publication 515, Reminders). IRS Table 3 shows its effective period as ending 2023-12-31 and the IRS treaty index marks it Treaty Terminated. No rate from this treaty applies today.

Is the US-Belarus tax treaty still in effect?

In part. The suspension covers one article of the US-USSR treaty, Article III(1)(g), scheduled to run until 2026-12-31. Belarus has no treaty of its own. The U.S.-U.S.S.R. income tax treaty, in force since 1987, applies (IRS Table 3, footnote 6). Operation of Article III(1)(g) is suspended by mutual agreement from 2024-12-17 until 2026-12-31 or earlier if the two governments decide.

Is the US-Russia tax treaty still in effect?

In part. The suspension covers every article that sets a withholding rate. Partly suspended, and the suspension covers every article that sets a rate. On 2024-07-01 the United States gave notice suspending Article 1(4), Articles 5 to 21 and Article 23 of the US-Russia treaty and its Protocol by mutual agreement, effective 2024-08-16 for taxes withheld at source and other taxes, continuing until the two governments decide otherwise (IRS Table 3, footnote 8; the IRS treaty index marks it Treaty Partially Suspended). No withholding rate from this treaty should be presented as available.

How do you claim a treaty rate?

A nonresident individual claims a lower treaty rate by giving the US payer Form W-8BEN, not by filing with the IRS. Without it, the payer may have to withhold the full 30%. The form names the country you claim residence in for treaty purposes, and generally stays valid through the end of the third calendar year after you sign it.

If you are a resident of both countries under their own laws and use a treaty tie-breaker to be treated as a resident of the other country, you file US Form 1040-NR as a nonresident and attach Form 8833 to disclose the treaty position. Failing to disclose a required position can cost an individual $1,000 per failure. For everything other than computing US income tax you are still treated as a US resident, and a green card holder of 8 of the last 15 years who makes this claim is treated as having ended US residency, which can trigger the expatriation tax (IRS Publication 519).

How do you prove US residency to a treaty country?

With Form 6166, a letter from the US Treasury certifying that you are a US resident for tax purposes. Many treaty countries require it before they apply the lower rate. You request it on Form 8802, and the user fee for an individual is $85 per application however many countries or years it covers; it is $185 for a business or other non-individual applicant (Form 8802 instructions). The IRS advises applying at least 45 days before you need it. Someone who filed as a nonresident, or who used a treaty tie-breaker to claim residence elsewhere, generally cannot get one.