What the paying country withholds

The rate a treaty names is a ceiling, not a rate. Where domestic law already withholds less, domestic law wins — which is why a UK dividend to almost anywhere is zero while the treaty column says 15. This page applies the lower of the two and tells you which one it took.

Pick the country making the payment, the country receiving it and the type of payment. The direction matters: the matrix is not symmetric, and the country that withholds is the one that pays. Where a treaty makes relief conditional on something that is not a percentage, the condition is printed in full rather than folded into the number.

Withheld by the paying country
0 %
treaty rate applied
Domestic rate, no treaty30 %
Treaty ceiling0 %
Conditionholding of at least 80 %
Treaty in force since2004-01-01
This is the residual rate

Where a treaty sets a lower step for a particular subtype of payment, that step is described in the conditions below and is not applied to the figure above.

Conditions that are not a number

For this pair there are conditions that do not reduce to a number — holding periods, type of payer or recipient, carve-outs. For now they are written up in Russian only. Read them before relying on the rate above.

Open this pair's note (in Russian) →
Collected so far: 380 of 380

A figure like this is classically read as one input to a structure, next to where the profit arises and how each entity is held — neither of which this page can see. Applying it to a specific structure is the work of Ignito.Advisory, and it is paid. The first conversation is free: thirty minutes under NDA, and you leave with a written statement of the problem and a proposed scope. Request a discovery call →

Informational resource curated by the Ignito legal practice and cross-checked against primary sources. This is not legal advice and does not create a lawyer-client relationship. Rules change — verify against the primary source before you sign or file.

International withholding tax: what each paying country withholds without a treaty

The domestic rate is the starting point: what the country of the payer withholds on dividends, interest and royalties paid abroad when no treaty, EU directive or domestic exemption reduces it. A treaty sets a ceiling below it; the calculator above applies the lower of the two for the pair you pick. Each row links to the primary source it was checked against.

Paying countryDividendsInterestRoyaltiesSource
Austria27.5 %27.5 %20 %source · 2026-09-04
Belgium30 %30 %30 %source · 2026-09-09
Cyprus0 %0 %10 %source · 2026-09-21
Estonia0 %0 %10 %source · 2026-09-24
France25 %0 %25 %source · 2026-08-29
Germany26.375 %0 %15.825 %source · 2026-08-25
Hong Kong0 %0 %4.95 %source · 2026-10-02
Ireland25 %20 %20 %source · 2026-08-26
Italy26 %26 %30 %source · 2026-08-31
Lithuania17 %0 %10 %source · 2026-09-25
Luxembourg15 %0 %0 %source · 2026-08-27
Malta0 %0 %0 %source · 2026-09-23
Netherlands15 %0 %0 %source · 2026-08-25
Poland19 %20 %20 %source · 2026-10-06
Singapore0 %15 %10 %source · 2026-10-08
Spain19 %19 %24 %source · 2026-08-30
Switzerland *35 %35 %0 %source · 2026-08-28
UAE0 %0 %0 %source · 2026-10-07
United Kingdom0 %20 %20 %source · 2026-08-23
United States30 %30 %30 %source · 2026-08-22

* Switzerland: the 35% on interest applies to bonds and bank deposits; interest on an ordinary loan is not subject to Swiss withholding tax. Royalties are outside the Swiss withholding tax.

What this does not cover

The principal purpose test and limitation-on-benefits articles are not here — they do not reduce to a number. Neither are EU directive exemptions, which frequently give zero where a treaty gives 5, 10 or 15. Where a treaty splits the rate by subtype of payment — copyright against film, equipment against know-how — this page shows the residual, higher step and describes the reliefs in words. The pairs not yet collected are shown as such.

Formula source: IRS, Table 1. Tax Rates on Income Other Than Personal Service Income · HM Revenue & Customs — UK tax treaties · OECD — MLI signatories and parties
formula checked 2026-08-31 · Free, no sign-up, nothing you type is sent to us.
A calculation under a general rule — not legal or tax advice. It cannot see your treaty position, your substance or the exceptions in your own documents. What the calculators are
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