Y2J
Tax Tools
Chapter 3 NRA withholding, gross-up & treaty rate reference
When a nonresident alien is promised a specific net payment, use this to determine the required gross amount and withholding.
Rates shown are maximum treaty rates (%). Actual rates may vary based on specific conditions, ownership thresholds, and recipient qualifications. Always verify against the applicable treaty text.
Article 11 — Dividends: 25% general rate; 12.5% if beneficial owner is a company holding ≥10% of voting stock.
Article 12 — Interest: 17.5% general rate; 0% for interest paid to the government or central bank.
Article 13 — Royalties: 15% general rate; 10% for industrial royalties (patents, know-how, etc.).
Article 20 — Private Pensions & Annuities: Generally taxable only in the country of residence, subject to conditions.
Article 23 — Teachers & Researchers: Exempt from host-country tax for up to 2 years.
Article 24 — Students & Trainees: Up to $3,000/year exempt for living expenses.