Americas Corridors

Quick Reference

Quick Reference

Field	Value
Jurisdiction	Americas (North, Central, South)
Corridors Covered	US-CA, US-MX, US-BR, BR-AR, CA-UK, MX-ES, BR-PT, CL-ES, CO-ES
Number of Corridors	9
Last Verified	May 2026
Key Note	US has NO treaty with Brazil. Brazil has limited treaty network. Latin American countries generally impose higher WHT rates than OECD average.

US → Canada

US → Canada Withholding Tax Rates (US-Canada Convention signed 26 September 1980, five Protocols (latest 2007). IRS Table 1.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	15%	Art X(2)(b)	CA domestic WHT 25%
Dividends — substantial (≥10% voting)	5%	Art X(2)(a)	Direct corporate investment
Interest — arm's length	0%	Art XI(1)	2007 Fifth Protocol eliminated
Interest — related parties	10%	Art XI	Related-party exception retained
Royalties — copyright/literary/artistic/software	0%	Art XII(2)(a)	Specific exemption
Royalties — other (patents, trademarks)	10%	Art XII(2)(b)	Industrial/commercial
Technical services	0%	Art VII/XIV	Business profits / independent services

Source: US-Canada Convention signed 26 September 1980, five Protocols (latest 2007). IRS Table 1. Special provisions: Fifth Protocol (2007) was transformative — eliminated arm's length interest WHT and merged independent personal services into business profits. Split royalty treatment is typical of Canadian treaty practice. Canada domestic WHT is 25% across the board. Comprehensive LOB. Cross-border pension rules (RRSP/RRIF recognition). This is the highest-volume bilateral tax treaty corridor in the world. Last verified: May 2026

US → Mexico

US → Mexico Withholding Tax Rates (US-Mexico Convention signed 18 September 1992. IRS Table 1.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	10%	Art 10(2)(b)	MX domestic WHT 10%
Dividends — substantial (≥10% voting)	5%	Art 10(2)(a)	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 — no fixed base

Source: US-Mexico Convention signed 18 September 1992. IRS Table 1. Special provisions: Three-tier interest rate structure is unique. Mexico domestic WHT varies: dividends 10%, interest 4.9-35%, royalties 25-35%. Portfolio dividend treaty rate (10%) matches Mexico's domestic rate. NAFTA/USMCA investment provisions interact with treaty. LOB article. Last verified: May 2026

US → Brazil

No comprehensive income tax treaty exists between the US and Brazil.

US → Brazil Domestic Rates (No Treaty)

Income Type	Rate	Notes
Dividends	0% (BR domestic)	Brazil does not withhold on dividends (unique globally)
Interest	15% (BR domestic)	IRRF; 25% if paid to tax haven
Royalties	15% (BR domestic)	IRRF; 25% if paid to tax haven
Technical services	15-25% (BR domestic)	IRRF depending on service type

Note: The US and Brazil have never concluded a comprehensive income tax treaty. Negotiations have been discussed for decades but no convention has been finalised as of May 2026. Brazil is not on the IRS A-to-Z list of US income tax treaties. US-source FDAP payments to Brazilian residents face default 30% US WHT with no treaty relief. Brazilian IRRF (15% general, 25% for tax haven recipients) applies to outbound payments with no treaty reduction to the US. However, Brazil uniquely does NOT withhold on dividend distributions. Last verified: May 2026

Brazil → Argentina

Brazil → Argentina Withholding Tax Rates (Brazil-Argentina DTA. PwC Argentina WHT table.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	15%	Art 10	BR does not impose domestic dividend WHT
Interest	15%	Art 11	AR domestic WHT 15.05-35%
Royalties — general	10%/15%	Art 12	Split by type
Technical services	15%	Art 12/14	Service fees

Source: Brazil-Argentina DTA. PwC Argentina WHT table. Special provisions: Brazil uniquely does not withhold on dividends — treaty rate relevant only from Argentine side. Argentina domestic WHT on interest is 15.05-35%, reduced by treaty. Royalties split: 10% for certain categories, 15% for others. Both countries have limited treaty networks. MERCOSUR economic integration provides trade benefits but does not affect treaty rates. Last verified: May 2026

Canada → UK

Canada → UK Withholding Tax Rates (Canada-UK Convention 1978, consolidated 2014. Modified by MLI (effective January 2020).)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	15%	Art 10	CA domestic WHT 25%
Dividends — substantial (≥10% voting)	5%	Art 10	Direct investment
Interest	10%	Art 11(2)	Government interest exempt
Royalties — copyright/patent/software	0%	Art 12(3)	Specific exemption
Royalties — other (trademarks, franchises)	10%	Art 12(2)	General rate
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: Canada-UK Convention 1978, consolidated 2014. Modified by MLI (effective January 2020). Special provisions: Mirror of UK→Canada rates. Split royalty rates are characteristic of Canadian treaty practice. Copyright, patent, and software royalties at 0% — critical for tech/media cross-border flows. MLI PPT applies since January 2020. Canada domestic WHT is uniformly 25%. Last verified: May 2026

Mexico → Spain

Mexico → Spain Withholding Tax Rates (Mexico-Spain Convention. PwC Mexico/Spain WHT tables.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	10%	Art 10	MX domestic WHT 10%
Dividends — substantial (≥25% capital)	5%	Art 10	Higher threshold (25%)
Interest — general	10%	Art 11	Standard rate
Interest — banks/FIs	4.9%	Art 11	Special bank rate
Royalties	10%	Art 12	All categories 10%
Technical services	0%	Art 7/14	Business profits / independent services

Source: Mexico-Spain Convention. PwC Mexico/Spain WHT tables. Special provisions: Spanish multinational investments in Mexico are substantial. 25% capital threshold for reduced dividends reflects older treaty practice. Mexico's 4.9% bank interest rate appears in multiple Mexican treaties. Spain domestic WHT: 19% on dividends to non-residents. Last verified: May 2026

Brazil → Portugal

Brazil → Portugal Withholding Tax Rates (Brazil-Portugal Convention. PwC Brazil WHT guidance.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	10%/15%	Art 10	10% if ≥25% capital; 15% otherwise
Interest	15%	Art 11	Standard rate
Royalties	15%	Art 12	Standard rate
Technical services	15%	Art 12/14	Service fees

Source: Brazil-Portugal Convention. PwC Brazil WHT guidance. Special provisions: Historic Lusophone corridor. Brazil does not impose domestic dividend WHT — treaty rate relevant only from Portuguese side. Portugal domestic WHT: 25% across categories. Both countries are in the CPLP (Community of Portuguese Language Countries). One of Brazil's oldest treaty relationships. Last verified: May 2026

Chile → Spain

Chile → Spain Withholding Tax Rates (Chile-Spain Convention. PwC Chile WHT table.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	10%	Art 10	CL domestic WHT 35% (credit system)
Dividends — substantial (≥20% capital)	5%	Art 10	Lower rate
Interest — general	15%	Art 11	Standard rate
Interest — banks/FIs	5%	Art 11	Bank rate
Royalties — copyright/literary/artistic	5%	Art 12	Cultural royalties
Royalties — other (industrial/commercial)	10%	Art 12	Industrial royalties
Technical services	0%	Art 7/14	Business profits / independent services

Source: Chile-Spain Convention. PwC Chile WHT table. Special provisions: Spain is a major investor in Chile. Chile's integrated tax system uses a credit mechanism for dividends. Split royalty rates (5%/10%). Two-tier interest (5%/15%). Chile domestic WHT on royalties is 30% — treaty provides significant reduction. Last verified: May 2026

Colombia → Spain

Colombia → Spain Withholding Tax Rates (Colombia-Spain Convention. PwC Colombia WHT guidance.)

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	10%	Art 10	CO domestic WHT 20%
Dividends — substantial (≥20% capital)	5%	Art 10	Lower rate
Interest	10%	Art 11	CO domestic WHT 15-20%
Royalties	10%	Art 12	CO domestic WHT 20%
Technical services	10%	Art 12	Included in royalties article

Source: Colombia-Spain Convention. PwC Colombia WHT guidance. Special provisions: Spain is a major FDI source for Colombia. Colombia domestic WHT: 20% on royalties, 15-20% on interest, 20% on dividends. Treaty provides meaningful reduction across all categories. Colombia is part of the Pacific Alliance and OECD. Last verified: May 2026

Summary: Americas Treaty Rate Comparison

Summary: Americas Treaty Rate Comparison

Corridor	Dividends (substantial)	Interest	Royalties	Key Feature
US → CA	5%	0% (arm's length)	0%/10%	Zero interest since 2007
US → MX	5%	4.9%/10%/15%	10%	Three-tier interest
US → BR	No treaty	15% (domestic)	15% (domestic)	No treaty exists
BR → AR	15%	15%	10%/15%	BR no dividend WHT
CA → UK	5%	10%	0%/10%	Split royalties
MX → ES	5%	4.9%/10%	10%	Bank rate 4.9%
BR → PT	10%	15%	15%	Lusophone corridor
CL → ES	5%	5%/15%	5%/10%	Split royalties
CO → ES	5%	10%	10%	OECD member

PE Threshold Notes — Americas

PE Threshold Notes — Americas

Corridor	Construction PE Threshold	Service PE	Notes
US → CA	12 months	None (Art XIV merged)	Fifth Protocol merged services into Art VII
US → MX	6 months	183 days in any 12-month period	Shorter than standard — monitor near-shoring
US → BR	No treaty	No treaty	Brazil domestic PE rules apply
BR → AR	6 months	6 months	Short threshold
CA → UK	12 months	None	Standard OECD
MX → ES	6 months	183 days	Mexico standard
CL → ES	6 months	183 days	Chile standard
CO → ES	12 months	183 days	Colombia standard

Mexico and Chile use 6-month construction PE thresholds — significantly shorter than the OECD 12-month standard. This is critical for infrastructure and energy projects.

Brazil's Treaty Network — Key Limitation

Brazil has one of the most limited treaty networks among major economies:

Brazil Treaty Partner Rates

Brazil Treaty Partner	Dividends	Interest	Royalties	Notes
Argentina	15%	15%	10%/15%	MERCOSUR partner
Chile	10%/15%	10%/15%	10%/15%	2026 Protocol cuts rates
Portugal	10%/15%	15%	15%	Historic Lusophone tie
Japan	12.5%	12.5%	12.5%/15%/25%	Category-dependent
India	10%/15%	10%/15%	10%/15%/25%	2022 Protocol (effective 2026)
France	10%/15%	10%/15%	15%/25%	Older treaty
Spain	10%/15%	10%/15%	10%/15%	Key EU partner

Notable absences from Brazil's treaty network: US, UK, Germany, Australia, Canada, Singapore, Netherlands. For these jurisdictions, Brazilian domestic IRRF rates apply with no treaty relief.

Key Observations

1. Brazil's unique position: Brazil does not impose WHT on dividend distributions and has a very limited treaty network (no US treaty). Brazil's IRRF of 15% (25% for tax haven recipients) applies to most outbound payments.

2. Latin American WHT rates are generally higher than OECD/European rates. Treaty negotiations tend to produce rates of 10-15% rather than 0-5%.

3. Mexico's bank interest rate of 4.9% appears in multiple Mexican treaties and is one of the lowest interest rates available in the Americas.

4. Canada's split royalty approach (0% copyright/software vs 10% industrial) is consistent across its treaty network and materially affects tech/media planning.

5. Near-shoring impact: Mexico's 6-month PE threshold requires careful structuring for US companies establishing manufacturing/service operations under USMCA.

6. Chile-Brazil 2026 Protocol: Brazil published Decree 12.863 on 3 March 2026 implementing the first amending protocol to the Brazil-Chile DTA. New reduced ceilings: dividends 10% (from 15%), interest 10% for qualifying banks, royalties 10%. Effective for income earned since January 2026.

7. India-Brazil 2022 Protocol: Notified by India on 3 March 2026, effective from 1 April 2026. Reduces dividend WHT to 10%/15% (from 15%/25%), interest to 10%/15%, and royalties to 10%/15%. Introduces separate FTS article at 10%.

Key Procedural Requirements

Key Procedural Requirements

Country	Form Required for Treaty Benefits	Notes
US	W-8BEN / W-8BEN-E	LOB certification required
Canada	NR301 (individuals) / NR302 (entities)	Declaration of eligibility
Mexico	No standard form; CoR required	Mexican tax authority format
Brazil	CoR + apostille or consular certification	Limited treaty network
Argentina	CoR from home country	Treaty benefits via domestic claim
Chile	CoR from home country	DTA claim at source
Colombia	CoR from home country	Treaty benefit claim via payer

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.