Treaty desk

The United States tax treaty network

The IRS treaty list as published, including the entries the IRS itself flags as terminated or partially suspended, and what a treaty does not do for a US person.

  • 68 jurisdictions listed
  • 3 flagged partially suspended
  • 1 flagged terminated

Source: Internal Revenue Service — IRS — United States income tax treaties A to Z (page last reviewed or updated 03-Jan-2026). Retrieved 19 August 2026.

The IRS page carries 69 entries. One of them, "United States Model", is the US model treaty text rather than a treaty partner, so the table below lists the remaining 68. The IRS's own CAUTION labels are reproduced: Hungary as Treaty Terminated, Belarus and Russia as Treaty Partially Suspended, and the entry for the Union of Soviet Socialist Republics as Treaty Partially Suspended for Belarus — that last one is a surviving Soviet-era treaty that still governs some successor states. The IRS states: "The United States has tax treaties with a number of foreign countries. Under these treaties, residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from U.S. taxes on certain items of income they receive from sources within the United States." There is no entry for the United Arab Emirates.

How United States’s treaties work in practice

01

Introduction to the US treaty network

The United States network is smaller than Canada's and it behaves differently, because US taxation starts from citizenship rather than residence. A US citizen or green-card holder is taxed on worldwide income wherever they live, and a treaty does not undo that. Almost every US treaty contains a saving clause that preserves the right to tax its own residents and citizens as though the treaty did not exist, subject to named exceptions.

So the first question on a US file is never "is there a treaty" but "which side of the saving clause is my client on". For a non-resident receiving US-source income, the treaty is doing real allocating work. For a US person abroad, the treaty mostly matters at the margins, and the heavy lifting is done by credits and exclusions under domestic law instead.

The list itself needs reading rather than scanning. The IRS flags one treaty as terminated and three entries as partially suspended, and it keeps a Soviet-era treaty on the list because it still governs some successor states. An entry's presence is not proof that a treaty currently operates between the two countries.

One absence is worth stating plainly, because it drives a lot of planning: there is no entry for the United Arab Emirates. A UAE resident receiving US-source income has no US income tax treaty to fall back on.

For the corridors this practice runs, see the Canada–US treaty and the US–India treaty.

02

How residence is decided

US domestic law makes you a resident by green card, by a substantial-presence day count, or by election, and it taxes citizens regardless of where they live. Two of those routes can catch someone who has never thought of themselves as American for tax purposes, which is why a US file starts with status rather than with income.

Where the other country also treats the person as resident, the treaty tie-breaker applies in the usual order — permanent home, centre of vital interests, habitual abode, nationality, then agreement between the authorities. A treaty tie-break away from the United States can change how a non-citizen is taxed, and it usually comes with a disclosure requirement attached: the position has to be claimed and reported, not merely held.

The saving clause is what stops the tie-breaker from helping a citizen. A US citizen who is treaty-resident elsewhere is still a US taxpayer on worldwide income; what the treaty and the credits do is decide who taxes first and who gives relief.

Companies face entity-level questions that have no equivalent in most other networks, because an entity treated as a partnership in one country and a corporation in the other can put treaty benefits out of reach for its owners. See the tie-breaker and dual residency.

03

What each income type is taxed on

Business profits. A treaty generally limits US taxation of a foreign enterprise's business profits to those attributable to a US permanent establishment. Without a treaty, the domestic test is broader, which is one of the clearest practical benefits of having one. See business profits and PE.

Dividends, interest and royalties. The US applies a statutory withholding rate to US-source payments to non-residents, and a treaty reduces it. The reduction commonly steps with the size of the holding for dividends, and some treaties exempt particular interest or royalty categories. The reduced rate is available only where the payee has certified its entitlement to the withholding agent before payment. See the dividends, interest and royalties articles and US withholding and treaty claims.

Employment and personal services. Short-stay relief follows the familiar conditions, and separate articles cover directors, entertainers, sportspeople, students and trainees — each with its own test. See employment income and students and trainees.

Pensions and retirement accounts. This is where US treaties earn their keep for individuals, because a treaty can decide whether growth inside a foreign plan is taxable before it is paid out. The answer is treaty-specific and it is not the same for every kind of account. See pensions and annuities. Social security coordination sits in separate totalization agreements — see totalization.

Real property. Gains on US real property have their own regime with its own withholding, and treaties generally leave the source country's taxing right intact rather than removing it.

04

Claiming relief — the documents required

US treaty relief runs on certification. A withholding agent applies the statutory rate unless the payee has given it a valid W-8 series certificate claiming treaty benefits — W-8BEN for an individual, W-8BEN-E for an entity — identifying the treaty article relied on and, where required, the limitation-on-benefits test the claimant satisfies.

Certificates go stale. They have a validity period, they are invalidated by a change of circumstances, and a taxpayer identification number is frequently a precondition for the claim rather than an optional extra. A payment made against an expired certificate is a payment made at the statutory rate.

Where a treaty position is taken on a US return rather than at source, it generally has to be disclosed on the return, and the disclosure is what makes the position visible and defensible. Taking a treaty-based position quietly is how a small saving becomes a penalty exposure.

In the other direction, a US resident claiming relief abroad is typically asked for IRS certification of US residency, applied for in advance and issued for a particular year. See certificates of residency and the withholding claim mechanics.

05

The MLI and anti-abuse rules

The United States has not signed the multilateral instrument, which makes it the exception in this guide. US treaties are updated the old way, one protocol at a time, so the currency of a US treaty depends entirely on when its own text was last amended and brought into force.

Instead of a multilateral purpose test, US treaties carry a detailed limitation-on-benefits article. It is a set of objective tests — publicly traded, ownership and base erosion, active trade or business, derivative benefits, and a discretionary route where none of them fits. A claimant has to identify which test it meets, and the W-8 series asks for exactly that. See limitation on benefits.

Beneficial ownership and conduit concerns are handled through those tests and through domestic anti-conduit rules rather than through a general purpose test. The practical effect is the same: an entity interposed to reach a treaty rate, with no substance behind it, does not get the rate. See treaty shopping and beneficial ownership.

Where two authorities disagree, the competent authority procedure applies, and several US treaties add arbitration for cases the authorities cannot resolve. See the competent authority route.

06

Where treaties are most often got wrong

Expecting a treaty to help a US citizen. The saving clause is in almost every US treaty, and it preserves US taxation of citizens and residents. Relief for a US person abroad usually comes from credits and exclusions, not from the treaty's allocating articles.

Reading a listed treaty as an operating treaty. The IRS list itself flags one treaty as terminated and three entries as partially suspended. Presence on the list is a starting point, not a status.

Assuming a treaty exists. There is no US income tax treaty with the United Arab Emirates, and the list is the fastest way to check any assumption of that kind before it is built into a structure.

Claiming a rate without naming the article and the test. A W-8 that does not identify the treaty article, or the limitation-on-benefits test relied on, is not a claim the withholding agent can act on.

Confusing income tax treaties with totalization agreements. They are separate networks with separate partner lists. A social security agreement does not reduce income tax withholding, and an income tax treaty does not settle which country's social charges apply.

The US desk's treaty work is set out here, with a fixed fee agreed before the work begins.

United States’s treaty partners and their published status

68 rows, transcribed from the source named above on 19 August 2026. Nothing has been renamed, merged or tidied — a table that no longer matches the page it cites cannot be checked against it.

  • In force — listed by the IRS with no caution label attached.
  • Partly suspended — the IRS marks this entry "CAUTION Treaty Partially Suspended".
  • Terminated — the IRS marks this entry "CAUTION Treaty Terminated".
United States — jurisdictions on the IRS income tax treaty list, with the IRS’s own caution labels. Retrieved 19 August 2026.
Jurisdiction as printedStatus as published
Armenia In force
Australia In force
Austria In force
Azerbaijan In force
Bangladesh In force
Barbados In force
Belarus Partly suspended
Belgium In force
Bulgaria In force
Canada In force
Chile In force
China In force
Cyprus In force
Czech Republic In force
Denmark In force
Egypt In force
Estonia In force
Finland In force
France In force
Georgia In force
Germany In force
Greece In force
Hungary Terminated
Iceland In force
India In force
Indonesia In force
Ireland In force
Israel In force
Italy In force
Jamaica In force
Japan In force
Kazakhstan In force
Korea In force
Kyrgyzstan In force
Latvia In force
Lithuania In force
Luxembourg In force
Malta In force
Mexico In force
Moldova In force
Morocco In force
Netherlands In force
New Zealand In force
Norway In force
Pakistan In force
Philippines In force
Poland In force
Portugal In force
Romania In force
Russia Partly suspended
Slovak Republic In force
Slovenia In force
South Africa In force
Spain In force
Sri Lanka In force
Sweden In force
Switzerland In force
Tajikistan In force
Thailand In force
Trinidad In force
Tunisia In force
Turkey In force
Turkmenistan In force
Ukraine In force
Union of Soviet Socialist Republics (USSR) Partly suspended
United Kingdom In force
Uzbekistan In force
Venezuela In force

Every country in the table links to the IRS's own page for that treaty, taken from the IRS A-to-Z list on 8 September 2026.

The other three desks

Each desk carries its own partner list and its own source line, because each authority publishes something different.

24-hour helpline: +1 (416) 619-0068

Need a treaty position checked, not guessed?

Send us the payment, the parties and how United States fits and we will tell you which article decides it, what has to be filed, and what it costs. The fee is agreed in writing before any work starts.

  • Fixed fees agreed before work starts
  • 18,000+ clients served over 15+ years
  • Offices in India, the USA, Canada and the UAE

What these engagements turn on

Case study 1

Withholding Reduced by the Right Article

Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.

Read how this one runs
Case study 2

Three Countries in One File and Two Treaties That Disagree

Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.

Read how this one runs
Case study 3

Withheld at the Statutory Rate When a Treaty Rate Applied

Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.

Read how this one runs
Case study 4

An Assignment Priced Without Counting the Days

Nearly every relief in a mobility file — treaty exemption, residence, social security — is decided by a day count that has to be evidenced. The engagement puts the tracking in place at the start, because it cannot be reconstructed at the end.

Read how this one runs
Case study 5

Two Passports, Two Returns, One Income

Dual citizenship does not let you choose which country taxes you. The work is establishing residence, applying the treaty article that governs each income type, and preparing both returns from one set of figures so they agree line for line.

Read how this one runs
Case study 6

A Canadian Working in the US on a Work Visa

Immigration status and tax residence are different tests, and a visa says nothing about which country taxes the salary. The file fixes residence, applies the employment article, and sequences the two returns so the credit lands where it is usable.

Read how this one runs
Case study 7

The Same Income Taxed Twice on Paper

Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.

Read how this one runs
Case study 8

The Deemed Sale That Happens on Death

Canada treats most capital property as sold at fair market value on death, so a terminal return can carry tax on gains nobody realised. Valuations and the order of the returns are what decide the figure.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.

Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

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Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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