Who the US has treaties with (relevant to our customers)
The US has comprehensive income tax treaties with ~65 countries including:
- United Kingdom — one of the most robust treaties the US has.
- India — DTAA covers withholding, business profits, and tiebreakers.
- Canada, Mexico, Germany, France, Netherlands, Spain, Australia, Japan, South Korea — among many others.
No comprehensive treaty with: UAE, Saudi Arabia, Qatar, Bahrain, Oman, Kuwait, Singapore (for individuals), Nigeria. Founders in these jurisdictions have no treaty-based relief and operate under default US rules.
What a treaty actually does
Three things most commonly matter to our customers:
- Reduced withholding rates on US-source FDAP income (dividends, interest, royalties) paid to a treaty-country resident. Default 30% → often 10–15%, sometimes 0%.
- Tie-breaker rules when an individual is dual-resident under both countries’ domestic rules. Determines which country has primary taxing right.
- Permanent-establishment thresholds — the treaty definition replaces the home country’s domestic PE rules for the covered pair.
How a treaty position is claimed
- On the US side: file Form 8833 (treaty-based disclosure) with the US return and provide W-8BEN to the US payer.
- On the home-country side: follow the local treaty-benefit procedure.
Why we route treaty questions to the expert desk
Treaty analysis is specific to the article, the paying party, and the facts of the transaction. Standard 5472 service does not include treaty analysis. If your fact pattern needs one — withholding, dual residency, PE — we scope it as an expert-desk engagement.
See also: W-8BEN, Permanent Establishment.