---
oa_review_kit: v1
guide_slug: eu-intra-rates
guide_version: eu-intra-rates@2026-05-23T06:28:22.555Z
archetype: other
---

# Review kit: EU Intra Rates

Thank you for reviewing this Guide. This kit is one file with three parts: how
to use it, an interview prompt for your AI, and the Guide itself.

## How to use this kit (3 steps, about 15 minutes)

1. Open the AI you already use (ChatGPT, Claude, Gemini, anything that reads
   markdown) and paste in everything from "INTERVIEW PROMPT" below, including
   the Guide at the end.
2. Your AI interviews you like a colleague, one question at a time. Just talk:
   war stories, walk-throughs, the mistakes you catch. No writing required.
3. Your AI writes your answers up as a single markdown file. Hand it back at
   openaccountants.com/skills/eu-intra-rates/handback (also linked from the Guide
   page: "Hand back your file"). What you added is published under your name
   and credential.

If your AI cannot produce the exact output format, hand back whatever you have:
a revised Guide file, a worksheet, or plain notes. We take those too, and a
person reviews them by hand. The format below is the one we can apply straight
away.

---

# INTERVIEW PROMPT (paste from here down into your AI)

You are interviewing a practising accountant about how they actually do the
work covered by the attached Guide ("EU Intra Rates", slug `eu-intra-rates`).
Interview them like a colleague doing a handover. Do not lecture. Ask ONE
question at a time and wait for the answer. Chase war stories and specifics:
what kind of client, which portal step, how big the penalty was.

The rates, thresholds, and citations are our job; we refresh those from primary
sources. Capture ONLY what is NOT derivable from law:

- order of operations, and what a wrong order corrupts
- what to ask a client before computing anything
- what to assume when a fact is unknown, and how it gets flagged
- the most-missed traps, with penalty size and who falls in
- how the portal or filing channel actually behaves
- what has to reconcile before anyone signs
- when to refuse the work and hand it to a human specialist

If the accountant corrects a rate, threshold, or deadline in the Guide along
the way, record it in the FACT CORRECTIONS table, but do not steer the
interview toward numbers.

## Questions to work through

Ask these in order, one at a time. Skip any the accountant has already covered;
follow up where a story has specifics worth pinning down. Each question is
tagged with the method slot(s) it feeds.

1. [sequence] Walk me through the last one of these you did for a real client, start to finish. What did you open first, and why that order?
2. [intake_questions] A new client sits down for this work. What are your first five questions before you touch a number?
3. [evidence] Which documents do you insist on seeing, and which do you take the client's word for?
4. [trap] When you review this work drafted by someone else, what mistake do you catch most often?
5. [conservative_default] When a key fact is unknowable at draft time, what do you assume, and how do you flag it?
6. [judgment_rule] When the law allows two routes, how do you actually pick, and what do you write down about the choice?
7. [cross_check] Before you sign, what has to reconcile with what, and how close is close enough?
8. [filing_mechanics] Walk me through the actual submission: the portal steps, the order things must happen in, what locks, what you can't undo.
9. [scope_gate] Which clients do you refuse or refer to a specialist for this work? What makes you stop?
10. [unsettled_law] Anything here you deliberately won't finalise right now because the rules are moving?
11. [handback_protocol] What exactly do you hand over at the end? What's in your working paper?

## Method slots (for tagging the write-up)

- `scope_gate` (Scope gate and refusals): when to stop and send the client to a human
- `sequence` (Order of operations): what order to do things in, and what a wrong order corrupts
- `intake_questions` (Client intake questions): what to ask a client before computing
- `evidence` (Documents and evidence): which documents to insist on, and what is draft-grade vs file-grade
- `judgment_rule` (Judgment rules): how a practitioner actually picks when the law allows two routes
- `conservative_default` (Conservative defaults): what to assume when a fact is unknowable at draft time
- `trap` (Traps and most-missed items): the mistakes everyone makes, what they cost, and who falls in
- `filing_mechanics` (Portal and filing mechanics): how submission actually works: channel, order, what locks
- `cross_check` (Cross-checks before signing): what has to reconcile with what before delivery, and how close is close enough
- `pattern_library` (Pattern library): how messy real-world data (bank lines, payout platforms) maps to tax categories
- `edge_case` (Edge-case playbook): the client situations that change the method, not just the numbers
- `unsettled_law` (Unsettled-law flags): what not to finalise right now, and why
- `handback_protocol` (Hand-back protocol): what the finished working paper contains and who reviews it

## Output format: oa-handback v1

When the interview is done, write the answers up as ONE markdown file in
exactly this shape. Fill in the reviewer's real name, credential, and email
(ask for them at the end if they have not come up). Every method block gets a
`### [method:<slot>]` heading where `<slot>` is one of the 13 slot ids
above. Keep `guide_slug` and `guide_version` exactly as given. Omit any
section the interview produced nothing for, but keep the headings that remain
exactly as shown. The `fact_key` column may be left blank when unknown.

```markdown
---
oa_handback: v1
guide_slug: eu-intra-rates
guide_version: eu-intra-rates@2026-05-23T06:28:22.555Z
reviewer_name: <full name>
reviewer_credential: <credential>        # free text: CPA, EA, ACCA, Steuerberater...
reviewer_email: <email>
verdict: <approve | corrections | unable>
---

## METHOD

### [method:filing_mechanics] <short title for this block>
<prose: the method block, written in second person, imperative>

### [method:intake_questions] <short title for this block>
- <question 1>
- ...

## FACT CORRECTIONS
| fact_key | current | correct | source |
|---|---|---|---|
| <fact key if known, else blank> | <value in the Guide> | <correct value> | <cite> |

## FLAGS
- [unsettled] <what not to finalise, and why>
- [refer] <situations to escalate to a human>

## NOTES
<anything that did not fit a method slot or a fact correction>
```

If for any reason you cannot produce this exact format, output the accountant's
corrections and methods as clear plain notes instead. The hand-back page
accepts plain notes and revised Guide files too; this format is an
optimization, never a gate.

---

# THE GUIDE UNDER REVIEW

<!-- guide: eu-intra-rates · version: eu-intra-rates@2026-05-23T06:28:22.555Z -->

---
name: eu-intra-rates
description: EU Intra-Community Treaty Rates
jurisdiction: GLOBAL
domain: cross-border
tax_year: 2025
---

# eu-intra-rates

## Quick Reference

**Quick Reference**

| Field | Value |
| --- | --- |
| Jurisdiction | EU Member States (intra-community) |
| Corridors Covered | DE-FR, DE-NL, DE-IT, DE-ES, FR-IT, FR-ES, FR-BE, NL-BE, ES-PT, IT-MT, AT-DE, SE-DK-NO (Nordic Convention) |
| Last Verified | May 2026 |
| Key Note | EU Parent-Subsidiary Directive (0% dividends, 10%+ holding) and Interest & Royalties Directive (0% for 25%+ associated companies) often override treaty rates. Treaty rates below apply when directives do NOT apply (below thresholds, unrelated parties, individuals). |

## When Do EU Directives NOT Apply?

The EU Parent-Subsidiary Directive and Interest & Royalties Directive eliminate WHT in many intra-EU situations, but they have limitations:

1. **Parent-Subsidiary Directive (2011/96/EU):** Requires minimum 10% shareholding for at least 2 years. Does not cover portfolio dividends or individuals.
2. **Interest & Royalties Directive (2003/49/EC):** Requires 25% direct shareholding between associated companies. Does not cover unrelated parties or individuals.
3. **Below-threshold situations:** When shareholding requirements are not met, bilateral treaty rates apply.
4. **Anti-abuse:** Both directives contain anti-abuse provisions; if denied, treaty rates are the fallback.

The treaty rates below are relevant when these EU-level exemptions do not apply.

## Germany → France

**Germany → France rates**  _(Germany-France Convention (revised). PwC Germany WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 9 | Below PSA threshold |
| Dividends — substantial (≥10% capital) | 5% | Art 9 | Between 10% and PSA threshold |
| Interest | 0% | Art 10 | Taxable only in residence state |
| Royalties | 0% | Art 11 | Taxable only in residence state |

**Source:** Germany-France Convention (revised). PwC Germany WHT table.
**Special provisions:** Both states agreed to 0% interest/royalties bilaterally regardless of relationship. PSA Directive covers most corporate dividends above 10%.
**Last verified:** May 2026

## Germany → Netherlands

**Germany → Netherlands rates**  _(Germany-Netherlands Convention. PwC Germany and Netherlands WHT tables.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥10% capital) | 10% | Art 10 | Intermediate rate |
| Dividends — substantial (≥25% capital) | 5% | Art 10 | Higher threshold for 5% |
| Interest | 0% | Art 11 | Taxable only in residence state |
| Royalties | 0% | Art 12 | Taxable only in residence state |

**Source:** Germany-Netherlands Convention. PwC Germany and Netherlands WHT tables.
**Special provisions:** Three-tier dividend rate (5%/10%/15%) — Germany uses capital percentage, not voting power. Netherlands conditional WHT does not apply to German payments (Germany is not low-tax). Treaty awaiting new protocol ratification.
**Last verified:** May 2026

## Germany → Italy

**Germany → Italy rates**  _(Germany-Italy Convention. PwC Germany and Italy WHT tables.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Italy domestic WHT 26% |
| Dividends — substantial (≥25% capital) | 10% | Art 10 | Older treaty — 25% threshold |
| Interest | 0%/10% | Art 11 | 0% for most; 10% for certain types |
| Royalties | 0%/5% | Art 12 | Split by royalty type |

**Source:** Germany-Italy Convention. PwC Germany and Italy WHT tables.
**Special provisions:** Older treaty with higher substantial-holding threshold (25%). Post-Brexit, Italy-UK Interest & Royalties Directive ceased — but intra-EU Italy-Germany directive still applies for qualifying associated companies. Italy domestic royalty WHT is 30% (applied on 75% of gross).
**Last verified:** May 2026

## Germany → Spain

**Germany → Spain rates**  _(Germany-Spain Convention. PwC Germany WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥10% capital) | 5% | Art 10 | Direct investment |
| Interest | 0% | Art 11 | Taxable only in residence state; 15% on profit-participating |
| Royalties | 0% | Art 12 | Taxable only in residence state |

**Source:** Germany-Spain Convention. PwC Germany WHT table.
**Special provisions:** 0% interest applies generally but 15% may apply to profit-participating debt. Spain domestic WHT on dividends to non-residents is 19%.
**Last verified:** May 2026

## France → Italy

**France → Italy rates**  _(France-Italy Convention. PwC France and Italy WHT tables.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Below PSA threshold |
| Dividends — substantial (≥10% capital) | 5% | Art 10 | Direct investment |
| Interest | 10% | Art 11 | NOT zero — older treaty |
| Royalties | 0%/5% | Art 12 | Split by type |

**Source:** France-Italy Convention. PwC France and Italy WHT tables.
**Special provisions:** Interest rate of 10% is higher than most intra-EU treaties. EU I&R Directive overrides to 0% for qualifying 25%+ associated companies. Italy WHT on royalties to France: 5% for some, 0% for qualifying associated companies under directive.
**Last verified:** May 2026

## France → Spain

**France → Spain rates**  _(France-Spain Convention. PwC France WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥10% capital) | 0% | Art 10 | Full exemption |
| Interest | 0%/10% | Art 11 | 0% general; 10% on certain types |
| Royalties | 0% | Art 12 | Full exemption |

**Source:** France-Spain Convention. PwC France WHT table.
**Special provisions:** 0% dividend for ≥10% holdings mirrors PSA Directive level. Spain domestic WHT 19% on dividends to non-residents.
**Last verified:** May 2026

## France → Belgium

**France → Belgium rates**  _(France-Belgium Convention. PwC France WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥10% capital) | 10% | Art 10 | Intermediate rate |
| Interest | 15% | Art 11 | Relatively high for intra-EU |
| Royalties | 0% | Art 12 | Full exemption |

**Source:** France-Belgium Convention. PwC France WHT table.
**Special provisions:** Interest rate of 15% is the highest in this set of intra-EU treaties. EU I&R Directive overrides to 0% for qualifying associated companies. Belgium 30% domestic WHT on dividends.
**Last verified:** May 2026

## Netherlands → Belgium

**Netherlands → Belgium rates**  _(Netherlands-Belgium Convention. PwC Netherlands WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥25% capital) | 5% | Art 10 | Higher threshold |
| Interest | 0%/10% | Art 11 | 0% general; exceptions apply |
| Royalties | 0% | Art 12 | Full exemption |

**Source:** Netherlands-Belgium Convention. PwC Netherlands WHT table.
**Special provisions:** 25% capital threshold for reduced dividend rate is higher than modern treaties. Belgium domestic WHT on dividends is 30%. Netherlands conditional WHT does not apply to Belgium (not low-tax jurisdiction).
**Last verified:** May 2026

## Spain → Portugal

**Spain → Portugal rates**  _(Spain-Portugal Convention. PwC Spain WHT tables.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥25% capital) | 10% | Art 10 | Older treaty threshold |
| Interest | 15% | Art 11 | Relatively high for intra-EU |
| Royalties | 5% | Art 12 | NOT zero |

**Source:** Spain-Portugal Convention. PwC Spain WHT tables.
**Special provisions:** Iberian corridor with older treaty terms. Both countries have relatively high domestic WHT rates. EU directives override for qualifying associated companies. Portugal domestic WHT: dividends 25%, interest 25%, royalties 25%.
**Last verified:** May 2026

## Italy → Malta

**Italy → Malta rates**  _(Italy-Malta Convention. PwC Italy WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥25% capital) | 5% | Art 10 | Direct investment |
| Interest | 10% | Art 11 | Standard rate |
| Royalties | 10% | Art 12 | Standard rate |

**Source:** Italy-Malta Convention. PwC Italy WHT table.
**Special provisions:** Key corridor for holding structures. Malta's full imputation system and 6/7ths refund mechanism interacts with treaty rates. EU PSA Directive applies for qualifying 10%+ holdings. Italy domestic WHT: dividends 26%.
**Last verified:** May 2026

## Austria → Germany

**Austria → Germany rates**  _(Austria-Germany Convention. PwC Germany WHT table.)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10 | Standard rate |
| Dividends — substantial (≥10% capital) | 5% | Art 10 | Direct investment |
| Interest | 0% | Art 11 | Taxable only in residence state |
| Royalties | 0% | Art 12 | Taxable only in residence state |

**Source:** Austria-Germany Convention. PwC Germany WHT table.
**Special provisions:** Austrian domestic WHT on dividends is 27.5%. Zero interest and royalties reflect close economic ties. Both countries use exemption-with-progression method. EU directives also provide 0% for qualifying associated companies.
**Last verified:** May 2026

## Nordic Convention: Sweden-Denmark-Norway

The Nordic Convention is a multilateral treaty between Denmark, Finland, Iceland, Norway, and Sweden.

### Sweden → Denmark

**Sweden → Denmark rates**  _(Nordic Convention 1996 (in force 1997). PwC Denmark, Sweden, Norway WHT tables.)_

| Income Type | Treaty Rate | Notes |
| --- | --- | --- |
| Dividends — portfolio | 15% | Denmark domestic WHT 27% |
| Dividends — qualifying company | 0% | EU PSA Directive / Nordic Convention |
| Interest | 0% | Denmark does not levy WHT on interest |
| Royalties | 0% | Full exemption |

### Sweden → Norway

**Sweden → Norway rates**  _(Nordic Convention 1996 (in force 1997). PwC Denmark, Sweden, Norway WHT tables.)_

| Income Type | Treaty Rate | Notes |
| --- | --- | --- |
| Dividends — portfolio | 15% | Norway domestic WHT 25% |
| Dividends — qualifying company | 0% | EEA participation exemption |
| Interest | 0% | Norway does not levy WHT on interest generally |
| Royalties | 0% | Full exemption |

### Denmark → Norway

**Denmark → Norway rates**  _(Nordic Convention 1996 (in force 1997). PwC Denmark, Sweden, Norway WHT tables.)_

| Income Type | Treaty Rate | Notes |
| --- | --- | --- |
| Dividends — portfolio | 15% | Standard rate |
| Dividends — qualifying company | 0% | Nordic Convention / EEA exemption |
| Interest | 0% | Neither country levies WHT on interest |
| Royalties | 0% | Full exemption |

## Nordic Convention: Sweden-Denmark-Norway

**Source:** Nordic Convention 1996 (in force 1997). PwC Denmark, Sweden, Norway WHT tables.
**Special provisions:** The Nordic Convention is a rare multilateral tax treaty. All three corridors are effectively 0% on interest and royalties. Dividend exemptions available through both the Nordic Convention and EEA participation exemption. TREKK Treaty governs collection/transfer between Nordic countries. Individual/portfolio dividends face 15% WHT. Sweden suspended its convention with Russia in February 2025.
**Last verified:** May 2026

## Summary: Intra-EU Zero-WHT Corridors (Treaty-Level, All Three Categories)

**Summary: Intra-EU Zero-WHT Corridors**

| Corridor | Dividends (substantial) | Interest | Royalties |
| --- | --- | --- | --- |
| DE ↔ FR | 5% | 0% | 0% |
| DE ↔ NL | 5% | 0% | 0% |
| DE ↔ ES | 5% | 0% | 0% |
| DE ↔ AT | 5% | 0% | 0% |
| FR ↔ ES | 0% (≥10%) | 0% | 0% |
| SE ↔ DK ↔ NO | 0% (qualifying) | 0% | 0% |

**Note:** With EU Parent-Subsidiary Directive and Interest & Royalties Directive, most intra-EU corporate payments between associated companies (≥25% for I&R, ≥10% for PSA) are at 0% regardless of treaty rates.

## EU Directive Quick Reference

### Parent-Subsidiary Directive (2011/96/EU)

**Parent-Subsidiary Directive (2011/96/EU) requirements**

| Requirement | Detail |
| --- | --- |
| Minimum shareholding | 10% of capital or voting rights |
| Holding period | At least 2 years (may be retroactive) |
| Company form | Listed in Directive Annex I |
| Subject to tax | Must be subject to corporate tax in an EU state |
| Result | 0% WHT on dividend distributions |
| Anti-abuse | GAAR introduced by 2015 amendment (2015/121/EU) |

### Interest & Royalties Directive (2003/49/EC)

**Interest & Royalties Directive (2003/49/EC) requirements**

| Requirement | Detail |
| --- | --- |
| Minimum shareholding | 25% direct holding of capital |
| Company form | Listed in Directive Annex |
| Subject to tax | Must be subject to corporate tax in an EU state |
| Relationship | Associated companies (direct 25% holding) |
| Result | 0% WHT on interest and royalty payments |
| Anti-abuse | Beneficial ownership and anti-abuse clause |

### When Directives Fail — Common Scenarios

1. **Portfolio investments:** Individual or fund holds <10% of capital → PSA Directive does not apply → treaty rate on dividends
2. **Unrelated parties:** No 25% ownership link → I&R Directive does not apply → treaty rate on interest/royalties
3. **Individuals:** Directives apply only to companies → individuals always fall back to treaty rates
4. **Anti-abuse denial:** Tax authority denies directive benefits under GAAR → treaty rate as fallback
5. **Third-country PE:** Income attributable to a PE outside the EU → directive may not apply
6. **Post-Brexit UK:** UK recipients no longer qualify for either directive → bilateral treaty rates apply

## PE Thresholds — Intra-EU Notable Deviations

**PE Thresholds — Intra-EU Notable Deviations**

| Corridor | Construction PE | Service PE | Notes |
| --- | --- | --- | --- |
| DE → FR | 12 months | None | Standard OECD |
| DE → NL | 12 months | None | Standard OECD |
| DE → IT | 12 months | None | Standard OECD |
| FR → ES | 12 months | None | Standard OECD |
| Nordic Convention | 12 months | None | Standard across Nordic countries |

Most intra-EU PE thresholds follow the OECD 12-month standard for construction projects, with no separate service PE provision.

## Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Treaty rates are subject to change through protocol amendments, renegotiations, and EU directive amendments. Always verify current treaty text and EU directive applicability before relying on any rate. All outputs must be reviewed by a qualified professional before filing or acting upon.