# us-major-partners

## Quick Reference

**Quick Reference**

| Field | Value |
| --- | --- |
| Jurisdiction | United States (source/residence) |
| Countries Covered | UK, Germany, France, Canada, Australia, Japan, India, Netherlands, Ireland, Switzerland, Singapore, Mexico, South Korea, Israel |
| Number of Treaties | 14 (note: no US treaty with Singapore or Hong Kong) |
| Last Verified | May 2026 |
| Key Note | US domestic WHT on FDAP income is 30%. Treaty benefits claimed via W-8BEN / W-8BEN-E. US LOB clauses are the most stringent globally. |

## US → UK

**US → UK income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2)(b) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2)(a) | Direct corporate investment |
| Dividends — parent (≥80% direct, 12+ months) | 0% | Art 10(3) | First US treaty with 0% dividend |
| Interest | 0% | Art 11(1) | Complete exemption |
| Royalties | 0% | Art 12(1) | Complete exemption |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-UK Convention signed 24 July 2001, amended by 2002 Protocol. IRS Table 1.
**Special provisions:** Comprehensive LOB (Art 23) — one of the strictest in US treaty network. Saving clause (Art 1(4)) preserves US taxing rights over citizens/residents. Branch profits tax reduced to 5%.
**Last verified:** May 2026

## US → Germany

**US → Germany income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Dividends — pension funds | 0% | Art 10 | Qualifying pension fund exemption |
| Interest | 0% | Art 11(1) | Complete exemption |
| Royalties | 0% | Art 12(1) | All categories 0% |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Germany Convention signed 29 August 1989, amended by Protocol. IRS Table 1.
**Special provisions:** 30% WHT on contingent interest not qualifying as portfolio interest. LOB clause. US has not signed MLI — treaty remains unmodified by MLI provisions.
**Last verified:** May 2026

## US → France

**US → France income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Interest | 0% | Art 11(2) | Complete exemption |
| Royalties | 0% | Art 12(1) | All categories 0% |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-France Convention signed 31 August 1994, amended by 2004 and 2009 Protocols. IRS Table 1.
**Special provisions:** MFN clause on royalties. US has not signed MLI. Branch profits tax provisions apply.
**Last verified:** May 2026

## US → Canada

**US → Canada income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art X(2) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art X(2) | Direct corporate investment |
| Interest — arm's length | 0% | Art XI(1) | Eliminated by 2007 Fifth Protocol |
| Interest — related parties | 10% | Art XI | Related-party exception |
| Royalties — copyright/literary/artistic/software | 0% | Art XII(2)(a) | Specific exemption |
| Royalties — other (patents, trademarks, industrial) | 10% | Art XII(2)(b) | Industrial/commercial royalties |
| Technical services | 0% | Art VII | Business profits — no WHT without PE |

**Source:** US-Canada Convention signed 26 September 1980, amended by five Protocols (latest 2007). IRS Table 1.
**Special provisions:** Split royalty rates mirror Canadian treaty practice. Fifth Protocol (2007) eliminated interest WHT on arm's length loans. LOB article. Canada domestic WHT is 25%.
**Last verified:** May 2026

## US → Australia

**US → Australia income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Interest | 10% | Art 11(2) | NOT zero — financial institution interest may qualify lower |
| Royalties | 5% | Art 12(2) | All categories 5% |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Australia Convention signed 6 August 1982, amended by Protocol 2001. IRS Table 1.
**Special provisions:** Australia franking credit system affects effective tax on dividends. Royalty definition is broader than OECD model. US domestic WHT 30% reduced significantly.
**Last verified:** May 2026

## US → Japan

**US → Japan income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 10% | Art 10(2) | Lower than typical 15% |
| Dividends — substantial (≥10% voting, 6 months) | 5% | Art 10(2) | Direct corporate investment |
| Dividends — parent (≥50% voting, 6 months) | 0% | Art 10(3) | 2013 Protocol addition |
| Interest | 0% | Art 11 | 2013 Protocol — zero rate |
| Royalties | 0% | Art 12(1) | All categories 0% since 2003 |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Japan Convention signed 6 November 2003, amended by 2013 Protocol (effective 30 August 2019). IRS Table 1.
**Special provisions:** 2013 Protocol was transformative — reduced interest to 0% and added 0% parent-subsidiary dividends. Anti-conduit provisions. LOB article. Portfolio dividend rate of 10% is lower than most US treaties.
**Last verified:** May 2026

## US → India

**US → India income types and treaty rates**  _(US-India Convention signed 12 September 1989)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — substantial (≥10% voting) | 15% | Art 10(2) | Still relatively high |
| Dividends — portfolio | 25% | Art 10(2) | Higher than most US treaties |
| Interest — general | 15% | Art 11(2) | NOT zero |
| Interest — banks/FIs | 10% | Art 11(2) | Banking business |
| Interest — government | 0% | Art 11(3) | Government exemption |
| Royalties — copyright | 15% | Art 12(2) | Literary/artistic |
| Royalties — industrial | 10% | Art 12(2) | Patents/equipment |
| Fees for included services | 15% | Art 12 | India-specific provision |
| Technical services | 15% | Art 12 | "Fees for included services" concept |

**Source:** US-India Convention signed 12 September 1989, Memorandum of Understanding 15 May 1989. US has NOT signed MLI — treaty unmodified.
**Special provisions:** Unique "fees for included services" concept (not FTS) — applies only where services make available technical knowledge. No US-India treaty amendment since original signing. India domestic WHT: 20% general. Treaty rates remain relatively high compared to newer US treaties.
**Last verified:** May 2026

## US → Netherlands

**US → Netherlands income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Interest | 0% | Art 12(1) | Complete exemption |
| Royalties | 0% | Art 13(1) | Complete exemption |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Netherlands Convention signed 18 December 1992, amended by Protocol 2004. IRS Table 1.
**Special provisions:** Netherlands conditional WHT (25.8%) applies only to low-tax jurisdictions — US is not affected. LOB article. One of the key holding company corridors.
**Last verified:** May 2026

## US → Ireland

**US → Ireland income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | W-8BEN required |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Interest | 0% | Art 11(1) | Complete exemption |
| Royalties | 0% | Art 12(1) | Complete exemption |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Ireland Convention signed 28 July 1997. IRS Table 1.
**Special provisions:** Critical corridor for US tech/pharma companies with Irish operations. LOB article. Ireland does not impose WHT on outbound dividends to treaty partners generally. Zero royalty rate is key for IP-heavy structures.
**Last verified:** May 2026

## US → Switzerland

**US → Switzerland income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | Swiss domestic WHT 35% |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Interest | 0% | Art 11(1) | Complete exemption |
| Royalties | 0% | Art 12(1) | Complete exemption |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Switzerland Convention signed 2 October 1996. IRS Table 1.
**Special provisions:** Swiss domestic WHT on dividends is 35% — treaty relief essential. Swiss refund procedure required (Form 82 / 83). LOB article. Contingent interest taxed at 30%.
**Last verified:** May 2026

## US → Singapore

**No comprehensive income tax treaty exists between the US and Singapore.**

**US → Singapore income types and domestic rates**

| Income Type | Rate | Notes |
| --- | --- | --- |
| Dividends | 30% (domestic) | No treaty reduction |
| Interest | 30% (domestic) | No treaty reduction |
| Royalties | 30% (domestic) | No treaty reduction |

**Note:** A limited bilateral agreement covers only shipping and air transport income. Singapore is absent from the IRS A-to-Z list of US income tax treaties. US-source FDAP payments to Singapore residents face 30% default withholding with no treaty relief.
**Practical note:** Most pure services performed entirely in Singapore are not US-source income and thus not subject to US withholding.
**Last verified:** May 2026

## US → Mexico

**US → Mexico income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 10% | Art 10(2) | Lower than typical 15% |
| Dividends — substantial (≥10% voting) | 5% | Art 10(2) | Direct corporate investment |
| Interest — general | 15% | Art 11(2) | Standard rate |
| Interest — banks/publicly traded bonds | 10% | Art 11(2) | Financial institution rate |
| Interest — certain bank/insurance | 4.9% | Art 11(2) | Special category |
| Royalties | 10% | Art 12(2) | All categories 10% |
| Technical services | 0% | Art 14 | Independent personal services |

**Source:** US-Mexico Convention signed 18 September 1992. IRS Table 1.
**Special provisions:** Three-tier interest rate structure (4.9%/10%/15%). Mexico domestic WHT varies by income type. LOB article. Independent personal services exempt if no fixed base in US.
**Last verified:** May 2026

## US → South Korea

**US → South Korea income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 15% | Art 10(2) | Standard rate |
| Dividends — substantial (≥10% voting) | 10% | Art 10(2) | Higher than typical 5% |
| Interest | 12% | Art 11(2) | Government interest exempt |
| Royalties — general | 15% | Art 12 | Industrial/commercial |
| Royalties — literary/artistic/motion picture | 10% | Art 12 | Cultural royalties |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-South Korea Convention signed 4 June 1976. IRS Table 1.
**Special provisions:** Older treaty with relatively high rates compared to modern US treaties. 10% substantial holding rate (vs typical 5%). Interest at 12% is unusually high. Social security totalization agreement also exists separately.
**Last verified:** May 2026

## US → Israel

**US → Israel income types and treaty rates**  _(IRS Table 1)_

| Income Type | Treaty Rate | Treaty Article | Notes |
| --- | --- | --- | --- |
| Dividends — portfolio | 25% | Art 12(2) | Unusually high |
| Dividends — substantial (≥10% voting) | 12.5% | Art 12(2) | Higher than most US treaties |
| Interest | 17.5% | Art 13(2) | Unusually high |
| Royalties — industrial | 10% | Art 14(1) | Patents/know-how |
| Royalties — copyright/films | 15% | Art 14(1) | Literary/artistic |
| Technical services | 0% | Art 7 | Business profits — no WHT without PE |

**Source:** US-Israel Convention signed 20 November 1975. IRS Table 1.
**Special provisions:** One of the oldest and least generous US treaties. Rates are well above modern standards. A new treaty has been under discussion for years. Israel domestic WHT: dividends 25-30%, interest 15-25%. The 25% portfolio dividend rate is the highest in the US treaty network.
**Last verified:** May 2026

## PE Threshold Notes

US treaty PE provisions generally follow the OECD model with some notable deviations:

**PE Threshold Notes table**

| Treaty Partner | Construction PE Threshold | Service PE | Notes |
| --- | --- | --- | --- |
| UK | 12 months | None specified | Standard OECD |
| Germany | 12 months | None specified | Standard OECD |
| France | 12 months | None specified | Standard OECD |
| Canada | 12 months | None specified | Merged Art XIV into Art VII |
| India | 90 days in any 12-month period | 90 days in any fiscal year | Very short threshold |
| Japan | 12 months | None specified | Standard OECD |
| Mexico | 6 months | 183 days in any 12-month period | Shorter than standard |
| South Korea | 6 months | None specified | Shorter than standard |
| Israel | 12 months | None specified | Standard OECD |

**Mexico's 6-month construction PE** is shorter than the standard 12 months — maquiladora/near-shoring operations require careful PE monitoring.

## LOB (Limitation on Benefits) Overview

US treaties contain the most stringent LOB provisions globally. The standard US LOB test requires the treaty claimant to satisfy at least one of the following:

1. **Qualified person test** — publicly traded company, government entity, pension fund, tax-exempt organisation, or individual
2. **Ownership and base erosion test** — ≥50% owned by qualifying residents AND <50% of gross income paid to non-residents
3. **Active trade or business test** — income is connected to an active business in the treaty country
4. **Discretionary benefits** — competent authority may grant benefits if denial would be inappropriate

All US treaties listed above (except the 1975 Israel treaty) contain LOB provisions. The UK and Canada treaties have the most developed LOB clauses.

## Summary: Zero-WHT Corridors (All Three Categories)

**Summary: Zero-WHT Corridors table**

| Corridor | Dividends (substantial) | Interest | Royalties |
| --- | --- | --- | --- |
| US ↔ UK | 5% (0% at 80%) | 0% | 0% |
| US ↔ Germany | 5% (0% pension) | 0% | 0% |
| US ↔ France | 5% | 0% | 0% |
| US ↔ Japan | 5% (0% at 50%) | 0% | 0% |
| US ↔ Netherlands | 5% | 0% | 0% |
| US ↔ Ireland | 5% | 0% | 0% |
| US ↔ Switzerland | 5% | 0% | 0% |

## 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 and renegotiations. Always verify current treaty text before relying on any rate. All outputs must be reviewed by a qualified professional before filing or acting upon.

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