Tax Treaty Coverage — Notable Country Pairs
Bilateral income-tax treaties define the withholding-tax caps that apply when dividends, interest or royalties flow across borders, establish tiebreaker rules for dual-residence disputes, and determine whether a totalization agreement reduces dual social-security liability. This table covers ~40 pairs of high-relevance to internationally mobile individuals and cross-border investors.
Last reviewed: 2026-06-01. Treaty rates can change via protocols and domestic rule changes — always verify with the relevant tax authority or a qualified adviser before relying on this table.
| Country pair | Treaty signed | Dividend WHT cap | Interest WHT cap | Royalty WHT cap | Tiebreaker rule | Totalization |
|---|---|---|---|---|---|---|
| USA – UK | 2001 (protocol 2002) | 5% (≥10% corporate); 15% (other); 0% (pension funds) | 0% | 0% | Residence first (competent-authority resolution) | Yes |
| USA – Canada | 1980 (5th protocol 2007) | 5% (≥10% corporate); 15% (other); 0% (pension/retirement) | 0% | 0% | Residence first (sequential tie-break: permanent home → centre of vital interests → habitual abode → nationality) | Yes |
| USA – Germany | 1989 (protocol 2006) | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| USA – France | 1994 (protocols 2004, 2009) | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| USA – Italy | 1984 (protocol 1999) | 5% (≥25% corporate); 15% (other) | 10% | 8% | Residence first | Yes |
| USA – Spain | 1990 (protocol 2013) | 5% (≥10% corporate); 15% (other) | 10% | 8% | Residence first | Yes |
| USA – Portugal | 1994 | 5% (≥25% corporate); 15% (other) | 10% | 10% | Residence first | No |
| USA – Mexico | 1992 (protocols 1994, 2002) | 5% (≥10% corporate); 10% (other) | 4.9–15% (rate depends on lender type) | 10% | Residence first | Yes |
| USA – Japan | 2003 (protocol 2013) | 5% (≥10% corporate); 10% (other); 0% (pension funds) | 0% | 0% | Residence first | Yes |
| USA – South Korea | 1979 (protocols 1980, 2000) | 10% (≥10% corporate); 15% (other) | 12% | 10–15% (industrial/scientific vs. other) | Residence first | Yes |
| USA – Australia | 1982 (protocols 2001, 2010) | 5% (≥10% corporate); 15% (other) | 10% | 5% | Residence first | Yes |
| USA – India | 1989 | 15% (≥10% corporate); 25% (other) | 15% | 15% (industrial/scientific); 20% (other) | Residence first | No |
| USA – Singapore | 1981 | 15% | 15% | 15% | Residence first | No |
| USA – UAE | N/A — no treaty in force | No treaty — domestic rates apply (UAE levies 0% most cases; US taxes residents worldwide) | No treaty — domestic rates apply | No treaty — domestic rates apply | N/A — no treaty | No |
| USA – Switzerland | 1996 (protocols 2003, 2010) | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| UK – Spain | 1975 | 10% (≥10% corporate); 15% (other) | 12% | 10% | Residence first | Yes |
| UK – France | 2008 | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first (sequential: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement) | Yes |
| UK – Portugal | 1968 (protocol 2000) | 10% (≥25% corporate); 15% (other) | 10% | 5% | Residence first | Yes |
| UK – Italy | 1988 | 5% (≥10% corporate); 15% (other) | 10% | 8% | Residence first | Yes |
| UK – Germany | 2010 | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| UK – UAE | 2016 | 0% (corporate); 15% (individual) | 0% | 0% | Residence first | No |
| UK – Singapore | 1997 (protocol 2012) | 0% (Singapore has no WHT on dividends — one-tier system) | 5% | 8% | Residence first | No |
| UK – Australia | 2003 | 5% (≥10% corporate); 15% (other) | 10% | 5% | Residence first | Yes |
| UK – New Zealand | 1983 (protocols 1994, 2004) | 15% | 10% | 10% | Residence first | Yes |
| UK – South Africa | 2002 | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | No |
| UK – India | 1993 | 10% (≥25% corporate); 15% (other) | 15% | 15% (industrial/scientific); 20% (other — or as per MFN clause) | Residence first | No |
| Germany – Switzerland | 1971 (protocols 1978, 1992, 2002, 2010) | 5% (≥20% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| Germany – UAE | 1995 | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | No |
| France – Switzerland | 1966 (protocols 1969, 1997, 2009) | 5% (≥10% corporate); 15% (other) | 0% | 5% | Residence first | Yes |
| Netherlands – UAE | 2007 | 5% (≥10% corporate); 10% (other) | 0% | 0% | Residence first | No |
| Singapore – UAE | 2018 | 0% (both jurisdictions levy 0% on dividends) | 0% | 5% | Residence first | No |
| Singapore – India | 1994 (protocol 2005, landmark 2016 protocol) | 10% (≥25% corporate); 15% (other) | 15% | 10% (industrial/scientific); 15% (other) | Residence first | No |
| India – Mauritius | 1983 (protocol 2016) | 5% (≥10% corporate); 15% (other) | 7.5% | 15% | Domicile first (citizenship-based tiebreaker under old treaty; revised toward OECD model in 2016) | No |
| Germany – France (EU intra) | 1959 (protocol 1989, 2001, 2015) | 5% (≥10% corporate); 15% (other) — both EU-Parent-Sub Directive 0% also applies | 0% | 0% | Residence first | Yes |
| Netherlands – Germany (EU intra) | 1959 (replaced by 2012 treaty) | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| France – Italy (EU intra) | 1989 | 5% (≥10% corporate); 15% (other) | 10% | 5% | Residence first | Yes |
| Spain – Germany (EU intra) | 1966 (protocol 2011) | 5% (≥10% corporate); 15% (other) | 0% | 0% | Residence first | Yes |
| Italy – Switzerland | 1976 (protocols; revised agreement 2015 + 2023 implementation) | 5% (≥20% corporate); 15% (other) | 12.5% | 5% | Residence first | Yes |
| Portugal – Switzerland | 1974 | 5% (≥25% corporate); 15% (other) | 10% | 5% | Residence first | Yes |
Per-pair notes
🇺🇸🇬🇧 USA – UK: One of the most comprehensive US treaties. Savings clause applies; US citizens taxed on worldwide income regardless. UK pension distributions generally taxable only in UK.
🇺🇸🇨🇦 USA – Canada: 5th Protocol eliminated WHT on cross-border interest and most royalties. RRSPs / RRIFs recognised as pension plans. Strong anti-hybrid provisions.
🇺🇸🇩🇪 USA – Germany: 2006 Protocol aligned treaty with OECD Model. Germans with US assets face savings clause; US citizens working in Germany retain US filing obligation.
🇺🇸🇫🇷 USA – France: French wealth tax (IFI) not covered by treaty — US citizens in France remain liable. French PEA tax advantages partially mitigated for US persons.
🇺🇸🇮🇹 USA – Italy: Older treaty; interest and royalty caps still apply at non-zero rates unlike newer US treaties. Italy's IVAFE and IVIE taxes on foreign assets are not addressed.
🇺🇸🇪🇸 USA – Spain: Spain's Beckham Law (special expat regime) can interact with treaty; not recognised by IRS for US citizens. WHT on interest and royalties remains above zero.
🇺🇸🇵🇹 USA – Portugal: No US-Portugal totalization agreement as of mid-2026 — dual social-security liability risk remains. NHR / IFICI regime interplay with treaty: relief available but US persons still file US returns.
🇺🇸🇲🇽 USA – Mexico: Interest rates staggered: 4.9% on bank/listed bonds, 10% other, 15% back-to-back or related parties. Treaty predates USMCA; generally well-functioning.
🇺🇸🇯🇵 USA – Japan: 2013 Protocol modernised to near-OECD Model. Japan's shakai-hoken social insurance not fully credited against US SE tax despite totalization. Retirement accounts (iDeCo, NISAs) not explicitly recognised.
🇺🇸🇰🇷 USA – South Korea: Older treaty with above-OECD WHT rates. Renegotiation discussions have been ongoing but no updated treaty concluded as of mid-2026. Korea's retirement funds not explicitly recognised.
🇺🇸🇦🇺 USA – Australia: Australia's superannuation funds not explicitly recognised by IRS as pension; ongoing ambiguity for US citizens. Franking credits not creditable against US tax.
🇺🇸🇮🇳 USA – India: Old treaty with high WHT caps well above current OECD norms. No totalization agreement; dual social-security contributions for cross-border employees. Renegotiation long discussed but no updated treaty in force.
🇺🇸🇸🇬 USA – Singapore: Old treaty with flat 15% WHT across all categories. Singapore has no capital-gains tax; but US persons remain taxed on global gains regardless. No totalization — dual CPF/Social Security liability possible.
🇺🇸🇦🇪 USA – UAE: The USA and UAE have no bilateral income-tax treaty. US citizens in the UAE remain fully taxed by the IRS on worldwide income with no treaty relief. UAE currently levies no income tax on individuals and 9% corporate tax (2023+). No totalization agreement either.
🇺🇸🇨🇭 USA – Switzerland: 2010 Protocol enhanced information-exchange provisions (banking-secrecy watered down). Swiss 35% Verrechnungssteuer refundable via treaty claim. Swiss pillar-2/3 pension arrangements not fully mirrored in US treaty benefits.
🇬🇧🇪🇸 UK – Spain: Old treaty — one of UK's oldest still in operation. Higher WHT rates reflect 1970s norms. Renegotiation explored but not finalised post-Brexit.
🇬🇧🇫🇷 UK – France: Modern treaty, OECD aligned. Post-Brexit UK residents in France remain under UK-France treaty (EU membership irrelevant). French non-residents with UK dividend income can claim 5% cap.
🇬🇧🇵🇹 UK – Portugal: Older treaty; interacts heavily with Portugal's NHR / IFICI regime for UK retirees. UK pension income source-taxable in UK under treaty (Art. 17); NHR exemption can effectively zero Portuguese tax for 10 years.
🇬🇧🇮🇹 UK – Italy: Italy's flat-tax regime (€100k p.a. for new residents) interacts with this treaty; UK-source income broadly exempt in Italy under the regime. Italian IES (inheritance/gift equivalent of IHT) not covered.
🇬🇧🇩🇪 UK – Germany: Modern treaty superseding 1964 version. Includes Directive-on-Directive supplement covering German real estate fund distributions. Post-Brexit, UK companies no longer benefit from EU Parent-Subsidiary Directive but treaty rates fill the gap.
🇬🇧🇦🇪 UK – UAE: UAE levies no personal income tax. Treaty primarily relevant for UK companies with UAE operations. No totalization agreement; National Insurance obligations for UK expats depend on posting duration.
🇬🇧🇸🇬 UK – Singapore: Singapore's one-tier tax system means dividends are paid from already-taxed corporate profits; no dividend WHT applies. Protocol reduced interest WHT from 12% to 5%.
🇬🇧🇦🇺 UK – Australia: Working Holiday Visa holders not entitled to treaty benefits as non-residents. UK pension income sourced in UK; Australian super taxable in Australia. Broad mutual assistance provisions.
🇬🇧🇳🇿 UK – New Zealand: Older treaty with 15% dividend cap above OECD norms. NZ has no WHT on fully imputed dividends in practice. Treaty reviewed in 2004; renegotiation discussions ongoing.
🇬🇧🇿🇦 UK – South Africa: SA's dividends-withholding tax at 20% (domestic) reduced to treaty rates. Exit tax applies to South Africans ceasing residence. No totalization: dual liability risk for UK nationals working in SA.
🇬🇧🇮🇳 UK – India: India's MFN clause in treaty: if India signs lower rates with another OECD nation, those lower rates automatically apply to the UK treaty. Equalisation levy (digital services) separate; treaty relief may not apply.
🇩🇪🇨🇭 Germany – Switzerland: Extensive treaty with Grenzgänger (frontier worker) provisions. Swiss cross-border workers pay income tax in Switzerland with a 4.5% salary levy to Germany. Lump-sum taxation (Pauschalbesteuerung) in Switzerland can complicate tiebreaker.
🇩🇪🇦🇪 Germany – UAE: Germany has an Erweiterte beschränkte Steuerpflicht (extended limited liability) rule: German citizens who move to low-tax countries remain liable on German-source income for 10 years. UAE's nil income tax makes this highly relevant.
🇫🇷🇨🇭 France – Switzerland: Frontier-worker provisions: workers residing in France and working in Geneva cantons subject to French tax on Swiss income above threshold. Forfait fiscal (Swiss lump-sum) does not alter treaty tiebreaker in France's view.
🇳🇱🇦🇪 Netherlands – UAE: Netherlands treats UAE as low-tax jurisdiction for CFC purposes but treaty still reduces WHT. Netherlands Box 3 wealth tax not addressed. Frequently used for holding structures via Dutch BV / UAE FreeZone.
🇸🇬🇦🇪 Singapore – UAE: Both countries are low/nil-tax for individuals; treaty mainly relevant for corporate flows and royalty payments on IP held in either jurisdiction. Singapore's one-tier dividend system and UAE's 0% personal income tax make this largely a corporate structuring treaty.
🇸🇬🇮🇳 Singapore – India: 2016 Protocol removed capital-gains exemption (old Art. 13) that made Singapore-India the dominant FDI routing; now grandfathered for pre-2017 investments only. Treaty critical for India-bound FDI flows through Singapore holding companies.
🇮🇳🇲🇺 India – Mauritius: Historically the single most-used treaty for India-inbound FDI due to zero capital-gains on Indian shares via Mauritius companies. 2016 Protocol phased out that benefit; source-based capital-gains taxation now applies since April 2019. Transition rules with reduced 50% gains rate applied 2017-2019.
🇩🇪🇫🇷 Germany – France (EU intra): Intra-EU directives (Parent-Subsidiary, Interest & Royalties) largely supersede treaty rates for qualifying corporate payers; individual investors still use treaty WHT caps. Frontier worker provisions for Alsace-Moselle region.
🇳🇱🇩🇪 Netherlands – Germany (EU intra): 2012 treaty fully modernised. Extensive frontier-worker provisions for residents near the Dutch-German border. EU directives also apply for corporate flows between qualifying entities.
🇫🇷🇮🇹 France – Italy (EU intra): Non-zero interest and royalty WHT despite intra-EU relationship. EU Interest & Royalties Directive reduces corporate royalty/interest WHT to 0% for qualifying entities, effectively superseding treaty in those cases.
🇪🇸🇩🇪 Spain – Germany (EU intra): 2011 Protocol modernised. Spanish Beckham Law (special expat regime) recipients are treated as non-residents for treaty purposes; German-source income taxed at source only. EU Parent-Subsidiary and I&R Directives apply for qualifying corporate flows.
🇮🇹🇨🇭 Italy – Switzerland: Frontier-worker treaty signed 2020, in force 2023: Italian workers in Swiss border cantons now taxable primarily in Switzerland (capped at 80% rate in Switzerland). Long-running Swiss-Italy banking disclosure dispute resolved. Non-zero interest WHT despite close ties.
🇵🇹🇨🇭 Portugal – Switzerland: Treaty predates Portugal's NHR regime; NHR residents in Portugal can claim reduced WHT on Swiss-source pension distributions. Swiss Verrechnungssteuer (35%) refundable via treaty claim to 15%.
How to read this table
- Dividend WHT capis the maximum withholding tax the source country may apply to dividends paid to a resident of the treaty partner. Lower corporate-ownership thresholds (e.g., "≥10% corporate") trigger a reduced rate because the recipient is viewed as a substantial shareholder rather than a portfolio investor.
- Interest and royalty WHT caps apply when interest or royalty payments cross borders. A 0% cap means no withholding is required at source — the recipient pays tax only in their country of residence.
- Tiebreaker rulesdetermine tax residency when an individual qualifies as a resident of both countries under domestic law. The standard OECD sequence is: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement. "Domicile first" treaties (older Commonwealth treaties in particular) use a different primary test.
- Totalization agreements (social-security treaties) are separate instruments from income-tax treaties. Without one, an employee working in one country while remaining an employee of a firm in another may owe social security contributions to both countries simultaneously.
- EU Parent-Subsidiary Directive and Interest & Royalties Directive reduce WHT to 0% for qualifying intra-EU corporate flows, often making the bilateral treaty rate irrelevant for European corporate groups — but treaty rates remain the applicable floor for individuals and non-EU-resident entities.
- Notable absence: the USA–UAE pair has no bilateral income-tax treaty. US citizens living in the UAE remain fully taxed on worldwide income by the IRS with no treaty relief available.
See also: Tax residency matrix · Apostille by country · Foreign property buyers.