US Tax Treaty Status by Country — The Founder's Reference Table

Last verified: 3 August 2026 against IRS Publication 901 and IRS Tax Treaty Tables (Table 3). Source of truth: IRS Publication 901 and the IRS treaty tables at irs.gov. Treaty status changes — check the IRS tables before relying on any row here.

Whether your country has an income tax treaty with the United States decides three practical things: whether reduced withholding rates are available on US-source income, whether relief from double taxation runs through a treaty mechanism or only through your own country's domestic law, and which article you claim on a Form W-8BEN.

There is no single accurate, founder-facing version of this table anywhere online. This is ours. It covers the markets our readers actually operate from.

Before the table: the mistake that costs the most

A treaty does not usually matter as much as founders think, and matters enormously in one case.

Services you perform in your own country for a US client are generally foreign-source income and generally not subject to US withholding at all — treaty or no treaty. When a US client withholds 30% from a freelancer, it is almost always because they had no valid Form W-8BEN on file. That is a paperwork failure, not a tax rule, and a treaty won't fix it.

Where a treaty genuinely changes the money is passive income — royalties, interest, dividends from US sources. If you license software or IP to a US company, the difference between the statutory 30% and a treaty rate is the whole margin on the arrangement.

The table

Status key: ✅ In force · ❌ No comprehensive treaty · ⚠️ Special situation

Asia-Pacific

Country	Status	Notes
India	✅	In force. Amex Global Transfer origin market.
Pakistan	✅	In force.
Bangladesh	✅	Signed Dhaka 27 Sep 2004; in force 7 Aug 2006.
Indonesia	✅	Signed 11 Jul 1988; in force 30 Dec 1990. Protocol 24 Jul 1996 (in force 23 Dec 1996) cut dividend/interest/royalty withholding 15% → 10%.
Philippines	✅	In force.
Sri Lanka	✅	In force.
Thailand	✅	In force.
Japan	✅	In force.
South Korea	✅	In force.
China	✅	In force.
Singapore	❌	No comprehensive income tax treaty. Counterintuitive for a market this developed — see our Singapore banking guide.
Hong Kong	❌	No comprehensive income tax treaty.
Malaysia	❌	No comprehensive income tax treaty.
Vietnam	❌	No comprehensive income tax treaty.

Europe

Country	Status	Notes
United Kingdom	✅	In force. Note: HMRC treats US LLCs as opaque while the US treats single-member LLCs as transparent — a mismatch the treaty does not cleanly resolve. Take advice before forming.
Germany	✅	In force. German CFC rules (Außensteuergesetz) apply separately.
Netherlands	✅	In force. Dutch entity-classification rules determine whether relief works as expected.
France	✅	In force.
Spain	✅	In force.
Italy	✅	In force.
Poland	✅	In force.
Turkey	✅	In force. Turkish CFC rules apply separately.
Ukraine	✅	In force.
Hungary	⚠️ TERMINATED	The US terminated the treaty on 8 July 2022. Termination effective for withholding on payments made on or after 1 Jan 2024. Content assuming it is still in force is wrong.
Russia	⚠️ SUSPENDED	US gave formal notice 1 Jul 2024; suspension of Art. 1(4)i, 5–21 and 23 effective 16 Aug 2024 and continuing.

Africa and Middle East

Country	Status	Notes
South Africa	✅	In force. SA CFC rules apply separately and are the bigger issue.
Egypt	✅	In force.
Morocco	✅	In force.
Tunisia	✅	In force.
Nigeria	❌	No treaty. Relief depends on Nigerian domestic law.
Kenya	❌	No treaty.
Ghana	❌	No treaty.
Rwanda	❌	No treaty.
Côte d'Ivoire	❌	No treaty.
Senegal	❌	No treaty.
Ethiopia	❌	No treaty.
United Arab Emirates	❌	No comprehensive income tax treaty. Less consequential given no UAE personal income tax — but no treaty relief on US-source income.
Saudi Arabia	❌	No comprehensive income tax treaty.

Americas

Country	Status	Notes
Canada	✅	In force. Canadian treatment of US LLCs is a genuine mismatch — take advice before forming.
Mexico	✅	In force. Also a confirmed Amex Global Transfer market.
Brazil	❌	No comprehensive treaty. Combined with Law 14.754/2023 taxing offshore entity profits annually, this is the harshest combination on this page.
Colombia	❌	No comprehensive treaty. ECE rules apply.
Chile	✅ NEW	Treaty entered into force 19 December 2023 — the first new US treaty in over a decade. Effective for withholding on payments made on or after 1 Feb 2024, and for tax years beginning on or after 1 Jan 2024. Much online content predates it.
Argentina	❌	No comprehensive income tax treaty.
Peru, Costa Rica, Panama, Guatemala, El Salvador, Ecuador, Bolivia, Paraguay, Uruguay	❌	None have a comprehensive US income tax treaty.
Venezuela	✅	In force.
Jamaica, Trinidad & Tobago, Barbados	✅	In force.

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How to use this if your country has a treaty

1. Identify your income type. Services, royalties, interest, dividends and capital gains are treated differently and sit under different articles.
2. Get the article right. Claiming the wrong article is worse than claiming nothing.
3. File Form W-8BEN with the payer — not with the IRS. It establishes your foreign status and is where you claim treaty benefits.
4. Some countries require a domestic step too. India requires Form 67 for foreign tax credit, filed before the return. Indonesia requires a DGT certificate of domicile. Check what applies at home.

How to use this if your country has no treaty

No treaty relief on US-source income — the statutory rate applies where withholding is due.

Double-taxation relief depends on your own country's domestic law, not on a treaty mechanism. Whether US tax paid can be credited at home is a question for a local practitioner.

But note what usually matters more: most foreign-owned US LLCs with no US-effectively-connected income pay no US federal income tax at all. So the common scenario isn't double taxation — it's a founder who owes tax at home and believed the US structure removed the liability. A treaty wouldn't have helped with that either.

What every founder owes regardless of treaty status

A foreign-owned single-member US LLC treated as a disregarded entity must file Form 5472 with a pro-forma Form 1120 every year, including years with zero activity. Penalties start at $25,000 per form, per year and escalate. See our Form 5472 guide.

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Does India have a tax treaty with the US?

Yes. The US–India income tax treaty has been in force since 1990. For a founder in India who owns a US LLC, the treaty provides reduced withholding rates on dividends, interest, and royalties paid from the US to India. However, India taxes its residents on worldwide income — meaning Indian tax residents owe Indian income tax on profits flowing through their US LLC, regardless of the treaty. The treaty reduces double taxation; it does not eliminate Indian tax liability. See our full guide: does India tax my US LLC income?

Does Nigeria have a tax treaty with the US?

No. There is no comprehensive US–Nigeria income tax treaty. Nigerian founders with US LLCs have no treaty-based relief on US-source income. Relief from double taxation depends entirely on Nigerian domestic law — specifically, whether Nigeria allows a foreign tax credit for US taxes paid. Nigeria does tax its residents on worldwide income, so profits from a US LLC are in principle taxable in Nigeria. See our full guide: does Nigeria tax my US LLC income?

Does the UAE have a tax treaty with the US?

No. There is no comprehensive US–UAE income tax treaty. However, this is less consequential than it sounds: the UAE does not impose personal income tax on individuals, so there is no UAE-side double taxation risk for most founders. The absence of a treaty matters primarily for US withholding on US-source income paid to UAE residents. See our full guide: does the UAE tax my US LLC income?

Does the UK have a tax treaty with the US?

Yes. The US–UK income tax treaty is one of the most comprehensive bilateral tax agreements in force. For UK founders with US LLCs, the treaty provides reduced withholding on dividends, interest, and royalties. The UK taxes its residents on worldwide income, so UK tax residents owe UK income tax on US LLC profits. The treaty reduces double taxation through a foreign tax credit mechanism, but UK founders still need to report US LLC income on their UK Self Assessment return.

Does Canada have a tax treaty with the US?

Yes, but with an important caveat. The US–Canada tax treaty has been in force since 1980 and is generally favourable. However, Canada does not recognise US LLCs as transparent entities for Canadian tax purposes — Canada treats a US LLC as a corporation. This creates a mismatch: the US treats the LLC as a pass-through (taxing the Canadian owner directly), while Canada taxes the LLC itself when it distributes profits. The result can be double taxation that the treaty does not fully resolve. Canadian founders should take specific advice before forming a US LLC. See our guide: best state for a non-resident LLC

Does Germany have a tax treaty with the US?

Yes. The US–Germany income tax treaty has been in force since 1990. Germany taxes its residents on worldwide income, so German founders with US LLCs owe German income tax on LLC profits. Germany generally recognises US LLCs as transparent entities (consistent with the US treatment), which means the foreign tax credit mechanism works as intended — US taxes paid reduce German tax liability. The treaty also provides reduced withholding rates on dividends, interest, and royalties.

Does Mexico have a tax treaty with the US?

Yes. The US–Mexico income tax treaty has been in force since 1994. Mexico taxes its residents on worldwide income, so Mexican founders with US LLCs owe Mexican income tax on LLC profits. Mexico is also a confirmed Amex Global Transfer market — see our Amex Global Transfer country eligibility guide for details on the credit-building opportunity this creates.

Does Brazil have a tax treaty with the US?

No. Brazil has no comprehensive income tax treaty with the US. This is the harshest combination on this page: Brazil taxes its residents on worldwide income, and Law 14.754/2023 (effective 2024) requires Brazilian tax residents to declare and pay Brazilian income tax annually on profits held in offshore entities — including US LLCs — even if those profits are not distributed. There is no treaty mechanism to reduce the resulting double taxation. Brazilian founders should take specific advice before forming a US LLC. See our full guide: does Brazil tax my US LLC income?

Does the Philippines have a tax treaty with the US?

Yes. The US–Philippines income tax treaty has been in force since 1982. The Philippines taxes its citizens on worldwide income regardless of residence — meaning Filipino citizens owe Philippine income tax on US LLC profits even if they live outside the Philippines. The treaty provides reduced withholding rates on US-source income but does not eliminate Philippine tax liability. See our full guide: does the Philippines tax my US LLC income?

Does South Africa have a tax treaty with the US?

Yes. The US–South Africa income tax treaty has been in force since 1998. South Africa taxes its residents on worldwide income, so South African tax residents owe South African income tax on US LLC profits. The treaty provides a foreign tax credit mechanism that reduces double taxation. South Africa is also a confirmed Amex Global Transfer market. See our full guide: does South Africa tax my US LLC income?

VERIFIED THIS PASS — ALL ROWS RESOLVED (3 Aug 2026) Source: IRS Publication 901 (rev. 09/2024) and IRS Tax Treaty Tables (Table 3, updated Feb 2026), irs.gov.

• Chile: treaty in force 19 Dec 2023 — CORRECTION, previously recorded as no-treaty
• Hungary: terminated 8 Jul 2022, effective 1 Jan 2024
• Russia: suspended, effective 16 Aug 2024
• Confirmed WITHOUT comprehensive treaty: Brazil, Argentina, UAE, Saudi Arabia, Singapore, Hong Kong, Malaysia, Vietnam, Colombia, Peru, Costa Rica, Panama, Guatemala, El Salvador, Ecuador, Bolivia, Paraguay, Uruguay, Nigeria, Kenya, Ghana, Rwanda, Côte d'Ivoire, Senegal, Ethiopia For more context, see whether Bangladesh taxes US LLC income. For more context, see whether Colombia taxes US LLC income. For more context, see whether Indonesia taxes US LLC income. For more context, see whether Kenya taxes US LLC income. For more context, see whether Mexico taxes US LLC income. For more context, see whether Pakistan taxes US LLC income. For more context, see whether Turkey taxes US LLC income.