Guide to Global Payroll Management - 2020 - E-11

This table lists the income tax rates on interest, dividends, royalties, and other income that is not effectively connected with the conduct of a U.S.
trade or business. The income code numbers shown in this table are the same as the income codes on Form 1042-S, Foreign Person's U.S.
Source Income Subject to Withholding.
In most cases, a net basis tax, rather than a reduced tax rate or exemption, applies if the income is attributable to a permanent establishment of the
taxpayer in the United States under the Business Profits article of the treaty.
If the Treaty Article Citation includes a "P," that refers to a protocol that amends the treaty article. See also Table 3 - List of Tax Treaties. A
reference to 2P or 5P would be to the 2nd protocol or the 5th protocol.

AS
AU
BG
BB
BE
BU
CA
CH

Australia....................
Austria.....................
Bangladesh................
Barbados..............

Belgium ................
Bulgaria ...................
Canada......................

China, People's Rep.
of......
Comm. of Independent
States*.............
Cyprus..bbb...................
Czech Republic........
CY
EZ

Code

10 z
0g

30

0n
13(2)
11(1)

III(1)(g)

10

15
15 w

15 dd,mm
10 dd,mm
15 mm

6
Paid by U.S.
Corporations-
General a
15 mm
15 w
15 mm
15 w rr

Interest ccc
1
Paid by U.S.
Treaty
Obligors-
Article
General
Citation
10 g, jj, nn
11(2) / P7
0 g,jj,ss
11(1)
10 g,bb,jj
11(2)
5 rr, z
11(1)
/1PIV;
2PII(6)
0 g,jj, ss
11(1)
5 g,dd,jj,z
11(1)-(3)
0 g,jj
XI(1) \
5P6(1)
10 z
10(2)

5
5w

30

10

5 dd,mm,oo
5 dd,mm
5 mm

Dividends
7
Qualifying for
Direct Dividend
Rate a, b, aaa
5 mm,oo
5w
10 mm
5 w, rr

12(2)
10(2)

None

Treaty
Article
Citation
10(2) / P6
10(2)
10(2)
10(2) /
1PIII(1);
2PII(6)
10(2)
10(2)
X(2) /
5P5(1)
9(2)

0f
0f

30

0t

0f
0f
15 ii

23(1)
19(1)(a)

none

17(1)
17(1)
XVIII(1) / 3P9;
5P13
17(1)

Pensions and Annuities
15
Pensions and
Treaty
Annuities d
Article
Citation
0
18(1)
0
18(1)(a)
0 f,q
19(1)
0f
18(1)(a)

This table is not a comprehensive guide to all eligibility requirements for every treaty rate of tax or exemption listed. You should review the text of
the treaty and the Treasury Department Technical Explanation accompanying the treaty, as well any relevant competent authority arrangements to
determine whether a reduced rate of tax or an exemption is available. See the Competent Authority Arrangements page on irs.gov.
This table does not provide guidance on how to identify the relevant treaty resident and whether that resident is entitled to a reduced rate of tax or
exemption set forth in this table. See, for example, Table 4, Limitation on Benefits, and Treas. Reg. §§ 1.881-3 and 1.894-1(d) for additional rules
on entitlement to treaty benefits.
This table should not be relied on to determine whether a U.S. tax resident is entitled to the listed rate of tax from a foreign treaty country, although
generally the treaty rates of tax are the same.

Income Code Number
Name







CAUTION:







Table 1. Tax Rates on Income Other Than Personal Service Income Under Chapter 3, Internal Revenue Code, and Income Tax Treaties
(Rev. Feb 2019)

Appendix E-Miscellaneous Lists and Tables

IRS Table 1: Withholding Tax Rates on Income Other Than Personal Service Income Under
Chapter 3, Internal Revenue Code, and Income Tax Treaties

E-11
http://www.irs.gov
Guide to Global Payroll Management - 2020

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