The US has 60+ income-tax treaties. They matter for two reasons: they cap withholding rates on cross-border income (dividends, interest, royalties), and they coordinate tax residency tiebreakers when both countries try to claim you. Here’s the verified 2026 matrix.
Last verified: May 26, 2026. Not tax advice.
How US double-tax treaties work
Each treaty has standard articles:
- Article 4 (Residence): tiebreaker if both countries claim you
- Article 10 (Dividends): caps US withholding on outbound dividends (typically 15%, sometimes lower)
- Article 11 (Interest): caps US withholding on outbound interest (typically 0-15%)
- Article 12 (Royalties): caps withholding (typically 0-15%)
- Article 18 (Pensions, Social Security): coordinates pension + SS taxation
Treaty matrix — selected popular expat destinations
Portugal (1995 treaty)
- Dividends: 15% / 5% if >10% ownership
- Interest: 10%
- Royalties: 10%
- US Social Security: treaty Article 18 makes it US-taxable only
- Totalization Agreement: YES
Spain (1990, updated 2013 protocol)
- Dividends: 15% / 5% if >10% ownership / 0% for pension funds
- Interest: 10% / 0% for related-party financing
- Royalties: 5-10%
- Totalization Agreement: YES
France
- Dividends: 15% / 5% if >10%
- Interest: 0%
- Royalties: 0%
- Totalization Agreement: YES
Germany
- Dividends: 15% / 5% if >10%
- Interest: 0%
- Royalties: 0%
- Totalization Agreement: YES
United Kingdom (2001 treaty)
- Dividends: 15% / 5% if >10% ownership / 0% in some cases
- Interest: 0%
- Royalties: 0%
- Totalization Agreement: YES
Italy
- Dividends: 15% / 5% if >25%
- Interest: 10%
- Royalties: 0-10%
- Totalization Agreement: YES
Mexico
- Dividends: 10% / 5% if >10%
- Interest: 4.9-15%
- Royalties: 10%
- Totalization Agreement: NO (US-Mexico SS coordination is patchwork)
Canada
- Dividends: 15% / 5% if >10%
- Interest: 0%
- Royalties: 0-10%
- Totalization Agreement: YES
Australia
- Dividends: 15% / 5% if >10%
- Interest: 10%
- Royalties: 5%
- Totalization Agreement: YES
Japan
- Dividends: 10% / 0% if >50% ownership for 6 months
- Interest: 0-10%
- Royalties: 0%
- Totalization Agreement: YES
Singapore
- NO income tax treaty with US
- Withholding rates are statutory (US default 30% on dividends/interest/royalties to non-treaty countries)
- Totalization Agreement: NO
UAE
- NO income tax treaty with US (signed but not ratified status)
- UAE charges 0% personal income tax
- No Totalization Agreement
Switzerland
- Dividends: 15% / 5% if >10% / 0% for pension funds
- Interest: 0%
- Royalties: 0%
- Totalization Agreement: YES
Brazil
- NO tax treaty with US
- 30% statutory withholding applies
- Totalization Agreement: YES (since 2018)
Argentina
- NO tax treaty with US
- 30% statutory withholding
- No Totalization Agreement
Thailand
- Dividends: 15%
- Interest: 10-15%
- Royalties: 5-15%
- Totalization Agreement: NO
Totalization Agreements list (Social Security coordination)
As of 2026 the US has Totalization Agreements with 30 countries: Argentina (not in force yet), Australia, Austria, Belgium, Brazil, Canada, Chile, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Luxembourg, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, South Korea, Spain, Sweden, Switzerland, United Kingdom, Uruguay.
If you’re self-employed in a Totalization country, you pay SS/equivalent in ONE country (typically the country of residence, or coverage country per agreement) — not both.
If you’re in a NON-Totalization country (Mexico, Singapore, UAE, Thailand, Cambodia, Vietnam, Argentina) and self-employed, you owe US SE tax (15.3%) on top of any local social-security obligation. This is a significant tax drag for nomads.
FAQ
Does a treaty mean I pay zero double tax?
Not necessarily — treaties COORDINATE taxation. You may still pay tax in both countries on the same income, but the second country gives you a credit for tax paid in the first. The treaty caps WITHHOLDING and sets priority rules; it doesn’t eliminate tax.
Should I rely on the LOB clause for treaty benefits?
Most modern US treaties have a Limitation on Benefits (LOB) article. If you’re a US citizen treaty-resident in the partner country, you typically qualify as a ‘qualified person’ for LOB. If you’re using a foreign company as an intermediary, LOB may deny treaty benefits. Get advice.
Treaty articles that matter most for expats
US double-tax treaties have dozens of articles. The ones expats need to understand:
- Article 4 (Residence): tiebreaker rules if both countries claim you. Permanent home → center of vital interests → habitual abode → nationality → mutual agreement.
- Article 10 (Dividends): caps US withholding rate on US-source dividends paid to treaty-country residents.
- Article 11 (Interest): caps US withholding on US-source interest paid to treaty-country residents.
- Article 12 (Royalties): caps US withholding on royalty payments.
- Article 14 (Independent Personal Services): rules for self-employed contractors with cross-border work.
- Article 15 (Dependent Personal Services): rules for employees of one country working in another (183-day rule + employer rules).
- Article 17 (Artistes and Athletes): performance income special rules.
- Article 18 (Pensions, Social Security): typically taxable in country of residence; often Social Security taxable only in country of source.
- Article 19 (Government Service): government salaries typically taxable only by employing government.
- Article 22 (Limitation on Benefits / LOB): prevents “treaty shopping” — strict rules on who qualifies as treaty resident.
- Article 23 (Relief from Double Taxation): defines how each country credits/exempts foreign tax paid.
Form W-8BEN and treaty benefits
To claim treaty benefits on US-source income, foreign-resident individuals file Form W-8BEN with the US payer. This document certifies your foreign tax residency + claims reduced withholding rate per applicable treaty. Form W-8BEN must be renewed every 3 years (or sooner if your status changes). Without proper W-8BEN, US default 30% withholding applies — much higher than treaty rates.
Tax treaty news 2024-2026
- US-Chile income tax treaty entered into force February 2024 (after 14 years in ratification limbo). Now provides US-Chile residents with reduced withholding rates on dividends, interest, royalties.
- US-Hungary treaty was unilaterally terminated by US in 2022 — no current treaty. US default 30% withholding applies to US-source payments to Hungarian residents (concerning for US-citizen Hungary residents using FTC).
- US-Spain treaty 2013 protocol fully in effect — includes 0% withholding on certain dividends + interest scenarios.
- US-Argentina + US-Brazil: still no income tax treaties as of mid-2026. Significant tax inefficiency for cross-border investment.
- US-UAE: signed but ratification incomplete; default rules continue.
Treaty + state tax interaction
US double-tax treaties bind US federal tax — they do NOT generally bind US state taxes. California, New York, and other states often ignore treaty provisions. This means: US-Portugal treaty exempts your US Social Security from Portuguese tax, but California can still claim you if you maintain California ties. Plan state-residency exit separately (see state residency exit guide).
Additional FAQ
How do I confirm if my country has a US treaty?
IRS Publication 901 lists all US income tax treaties + selected treaty rates. Current US Treasury treaty page: treasury.gov/resource-center/tax-policy/treaties. For specific articles, the full text of each treaty is on IRS website. Talk to a cross-border CPA for interpretation of specific treaty provisions for your situation.
Tax treaties + state of residence — common confusion
Treaty residency (Article 4) determines which country has primary taxing authority over income. State residency in US determines whether a US state can tax you. These are independent concepts — you can be treaty-resident of Portugal but still tax-resident of California if you haven’t formally broken California domicile.
Related: FEIE 2026 · US-Portugal tax treaty.
✓ Last verified: May 26, 2026. Tax + banking content is general information, not advice. Talk to a licensed cross-border CPA or attorney for your specific situation.