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.