Tax Treaty Matrix
Bilateral tax-treaty status across the 46 jurisdictions in the TaxAtlas dataset. Sorted by usefulness for a US audience — jurisdictions with a US tax treaty plus a Social Security totalization agreement appear first.
What each column means
- Total treaties
- Approximate count of bilateral income-tax treaties in force, rounded. The UK and France lead globally with 100+. Pure-zero-tax jurisdictions (Cayman, BVI, Bahamas) have very few — they rely on Tax Information Exchange Agreements (TIEAs) instead.
- US / UK / Germany tax treaty
- Whether a bilateral income-tax treaty with that specific country is in force. Treaties typically reduce withholding-tax rates on cross-border dividends, interest, and royalties, plus include residency tie-breaker rules. The US is the gating question for US-citizen cross-border planning.
- US totalization
- A separate agreement covering Social Security coordination — prevents double-payment of FICA / SE tax for Americans working in the partner country. The list is much narrower than the tax-treaty list. US citizens working in a non-totalization country may owe US SE tax on top of local social charges with no offset.
- FATCA IGA
- Foreign Account Tax Compliance Act Intergovernmental Agreement. Model 1 (most common) has the local authority exchange information with the IRS; Model 2 has local foreign financial institutions report directly. “No IGA” means FATCA still applies via direct FFI reporting but with friction.
Jurisdiction-by-jurisdiction matrix
| Jurisdiction | Total treaties | US tax treaty | UK tax treaty | Germany treaty | US totalization | FATCA IGA |
|---|---|---|---|---|---|---|
| 🇬🇧United Kingdom | ~135 | Model 1 | ||||
| 🇫🇷France | ~125 | Model 1 | ||||
| 🇨🇭Switzerland | ~110 | Model 2 | ||||
| 🇮🇹Italy | ~105 | Model 1 | ||||
| 🇩🇪Germany | ~100 | Model 1 | ||||
| 🇳🇱Netherlands | ~100 | Model 1 | ||||
| 🇨🇦Canada | ~95 | Model 1 | ||||
| 🇪🇸Spain | ~95 | Model 1 | ||||
| 🇵🇹Portugal | ~80 | Model 1 | ||||
| 🇮🇪Ireland | ~75 | Model 1 | ||||
| 🇬🇷Greece | ~60 | Model 1 | ||||
| 🇦🇺Australia | ~50 | Model 1 | ||||
| 🇲🇹Malta | ~75 | Model 1 | ||||
| 🇧🇬Bulgaria | ~70 | Model 1 | ||||
| 🇨🇾Cyprus | ~70 | Model 1 | ||||
| 🇪🇪Estonia | ~65 | Model 1 | ||||
| 🇹🇭Thailand | ~65 | Model 1 | ||||
| 🇲🇽Mexico | ~60 | Model 1 | ||||
| 🇵🇭Philippines | ~45 | Model 1 | ||||
| 🇺🇾Uruguay | ~25 | Model 1 | ||||
| 🇦🇪United Arab Emirates | ~145 | Model 1 | ||||
| 🇸🇬Singapore | ~95 | Model 1 | ||||
| 🇭🇺Hungary | ~85 | Model 1 | ||||
| 🇶🇦Qatar | ~85 | Model 1 | ||||
| 🇰🇼Kuwait | ~80 | Model 1 | ||||
| 🇲🇾Malaysia | ~80 | Model 1 | ||||
| 🇺🇸United States | ~70 | No IGA | ||||
| 🇬🇪Georgia | ~60 | Model 1 | ||||
| 🇭🇰Hong Kong | ~50 | Model 2 | ||||
| 🇧🇭Bahrain | ~45 | Model 1 | ||||
| 🇲🇺Mauritius | ~45 | Model 1 | ||||
| 🇲🇨Monaco | ~35 | Model 1 | ||||
| 🇬🇮Gibraltar | ~30 | Model 1 | ||||
| 🇬🇬Guernsey | ~25 | Model 1 | ||||
| 🇯🇪Jersey | ~25 | Model 1 | ||||
| 🇮🇲Isle of Man | ~20 | Model 1 | ||||
| 🇵🇦Panama | ~15 | Model 1 | ||||
| 🇨🇷Costa Rica | ~12 | Model 1 | ||||
| 🇵🇾Paraguay | ~10 | Model 1 | ||||
| 🇰🇾Cayman Islands | ~5 | Model 1 | ||||
| 🇧🇲Bermuda | ~4 | Model 2 | ||||
| 🇻🇬British Virgin Islands | ~3 | Model 1 | ||||
| 🇦🇮Anguilla | — | Model 1 | ||||
| 🇧🇸Bahamas | — | Model 1 | ||||
| 🇹🇨Turks and Caicos | — | Model 1 | ||||
| 🇻🇺Vanuatu | — | Pending |
Sorted: US tax treaty + totalization first, then by treaty-network size, then alphabetical.
What this matrix tells you
- For US citizens moving abroad: jurisdictions with both a US tax treaty AND a totalization agreement (Canada, UK, Germany, France, Italy, Spain, Netherlands, Australia, Switzerland, Portugal, Greece, Ireland) are the cleanest from a paperwork perspective — Foreign Tax Credit works, treaty tie-breakers apply, and no double Social Security payment. Popular tax-driven destinations (UAE, Singapore, Cyprus, Malta, Hong Kong) have no US treaty and no totalization; FEIE + FTC remain available but the structure is more friction.
- For UK residents moving abroad: the UK’s treaty network is the largest globally — almost every TaxAtlas jurisdiction has a UK treaty in force. Exceptions are limited to Bahamas, Anguilla, Turks & Caicos, Vanuatu, Cayman, BVI, Bermuda, Costa Rica, Paraguay, and Monaco. For the post-non-dom UK FIG regime, the destination treaty position usually matters less than the UK’s own residence rules.
- For founders structuring holding companies: the historical “Mauritius route” for India-bound investment and the Cyprus / Malta / Ireland / Netherlands holding-co stacks all depend on treaty coverage with the source country. Pillar Two now bites the corporate-rate advantage for in-scope MNEs (see the Pillar Two tracker), but treaty network coverage still matters for withholding-rate reduction and dispute resolution.
- For pure tax-haven offshore use: Cayman, BVI, Bahamas, Anguilla, Turks & Caicos, Vanuatu, Bermuda have minimal treaty networks. They rely on TIEAs (information exchange) rather than full bilateral treaties. Useful for entities below the Pillar Two threshold; less useful when source-country withholding tax on inbound dividends/interest is the binding constraint.
- Special case — US-Hungary treaty terminated 2024: the US terminated its tax treaty with Hungary in 2024 over treaty-shopping concerns. Re-negotiation has not concluded. Any US-parented structures with Hungarian entities lost treaty protection — verify current planning if affected.
Per-jurisdiction notes
🇬🇧United Kingdomexpand
Largest treaty network globally. US-UK treaty includes detailed savings clause for US citizens, treaty benefits limitation, and protocol updates. Totalization agreement in force.
HMRC — Tax Treaties🇫🇷Franceexpand
US-France treaty has notable carveouts for French pensions and savings instruments. Totalization in force.
Bercy — Conventions fiscales🇨🇭Switzerlandexpand
US-Switzerland treaty has detailed pension and savings articles; updated protocol on information exchange. Switzerland uses Model 2 FATCA IGA (entity-level reporting) — distinct from most other major jurisdictions.
Swiss Federal Tax Administration🇮🇹Italyexpand
US-Italy treaty with pension and savings clause articles. Italian flat-tax regime (HNW lump-sum) compatible with treaty residency. Totalization in force.
Agenzia delle Entrate🇩🇪Germanyexpand
US-Germany treaty includes pension article (Article 18) and detailed treaty-benefits limitation. Totalization in force since 1979.
Bundesministerium der Finanzen🇳🇱Netherlandsexpand
US-Netherlands treaty includes detailed pension and savings articles. Strong treaty network is one of the historic drivers of Dutch holding-company structures.
Belastingdienst🇨🇦Canadaexpand
US-Canada treaty is one of the most-detailed tax treaties globally; tie-breaker rules and savings clause specifics matter for cross-border US citizens. Totalization in force.
Canada Revenue Agency — Tax Treaties🇪🇸Spainexpand
US-Spain treaty includes savings clause and limitation-on-benefits provision. Totalization in force.
Agencia Tributaria — Convenios🇵🇹Portugalexpand
US-Portugal treaty critical for NHR/IFICI planning (treaty benefits coordination with the special regime). Totalization in force.
Portuguese Tax Authority🇮🇪Irelandexpand
US-Ireland treaty is a cornerstone of US-parented IP-holding structures. Totalization in force.
Revenue Ireland🇬🇷Greeceexpand
US-Greece treaty is one of the older in force (1950s-era, updated). Greek 7% pensioner flat tax interacts with US treaty differently than NHR — verify before relying.
Greek Tax Authority (AADE)🇦🇺Australiaexpand
US-Australia treaty with savings clause and detailed pension articles. Totalization in force.
Australian Taxation Office🇲🇹Maltaexpand
US-Malta treaty (in force from 2010) is a relatively newer agreement. No US totalization. Malta non-dom regime treaty position is well-documented.
PwC Worldwide Tax Summaries — Malta🇧🇬Bulgariaexpand
US-Bulgaria treaty (2007, in force from 2008). No US totalization. Wide EU treaty network.
PwC Worldwide Tax Summaries — Bulgaria🇨🇾Cyprusexpand
US-Cyprus treaty in force. No US totalization. Cyprus non-dom regime coordinates with treaty residency — useful for US-citizen non-doms.
PwC Worldwide Tax Summaries — Cyprus🇪🇪Estoniaexpand
US-Estonia treaty (1999) in force. No US totalization. Estonia's distributed-profits-only corporate tax coordinates with US treaty for inbound investment.
PwC Worldwide Tax Summaries — Estonia🇹🇭Thailandexpand
US-Thailand treaty (1996) in force. No US totalization. ASEAN-wide network.
Thai Revenue Department🇲🇽Mexicoexpand
US-Mexico treaty critical for cross-border US-citizen planning. No US totalization, despite the size of the bilateral migration corridor.
SAT — Convenios Internacionales🇵🇭Philippinesexpand
US-Philippines treaty in force. No US totalization.
BIR — Bureau of Internal Revenue🇺🇾Uruguayexpand
No US tax treaty but US totalization in force (rare combination). UK and Germany treaties in force.
PwC Worldwide Tax Summaries — Uruguay🇦🇪United Arab Emiratesexpand
One of the largest treaty networks globally for a non-OECD jurisdiction. No US treaty despite extensive network — US-UAE bilateral negotiations have not produced one. UK and most EU treaties in force.
UAE Ministry of Finance — Tax Treaties🇸🇬Singaporeexpand
No US tax treaty — a long-standing gap that has shaped Singapore's competitive positioning vs Hong Kong. UK treaty in force, extensive Asia-Pacific network.
IRAS — Tax Treaties🇭🇺Hungaryexpand
US-Hungary treaty was terminated by the US in 2024 over treaty-shopping concerns. Re-negotiation has not concluded. This is a major change for US-parented Hungarian holdings.
KPMG — US-Hungary treaty termination🇶🇦Qatarexpand
No US tax treaty. UK treaty in force. Extensive treaty network with MENA, Asia, and several EU jurisdictions.
Qatar General Tax Authority🇰🇼Kuwaitexpand
No US treaty. UK and several EU treaties in force.
PwC Worldwide Tax Summaries — Kuwait🇲🇾Malaysiaexpand
No US tax treaty. UK and Germany treaties in force. ASEAN double-tax treaty network well established.
PwC Worldwide Tax Summaries — Malaysia🇺🇸United Statesexpand
The US is the originator of the FATCA regime — it does not itself have an IGA. US treaty network is selective compared to the UK's and is gated by limitation-on-benefits provisions. Treaty with Hungary terminated 2024.
IRS — United States Income Tax Treaties A to Z🇬🇪Georgiaexpand
No US tax treaty. UK and Germany treaties in force. Treaty network covers most CIS and major EU partners.
PwC Worldwide Tax Summaries — Georgia🇭🇰Hong Kongexpand
No US tax treaty (long-standing gap). UK treaty in force. Uses Model 2 FATCA IGA. Smaller treaty network than Singapore but covers major Asia-Pacific partners.
Inland Revenue Department (IRD)🇧🇭Bahrainexpand
Smaller treaty network than UAE/Qatar but covers UK and most major Asia/MENA partners. No US tax treaty.
PwC Worldwide Tax Summaries — Bahrain🇲🇺Mauritiusexpand
No US tax treaty (the historic Mauritius-India treaty was renegotiated to remove the most aggressive treaty-shopping benefits in 2017). UK, France, India, China all in force.
Mauritius Revenue Authority🇲🇨Monacoexpand
No US, UK, or Germany tax treaty. France-Monaco treaty (1963) is the dominant bilateral arrangement and the reason French citizens remain subject to French tax. Smaller treaty network reflects Monaco's 0% individual income tax regime.
PwC Worldwide Tax Summaries — Monaco🇬🇮Gibraltarexpand
No US tax treaty. UK treaty in force (Gibraltar is a British Overseas Territory). Smaller treaty network than typical EU jurisdictions.
HM Government of Gibraltar🇬🇬Guernseyexpand
No US tax treaty. UK treaty in force. Smaller treaty network than Jersey but increasing.
States of Guernsey Revenue Service🇯🇪Jerseyexpand
No US tax treaty. UK treaty in force. Jersey is a Crown Dependency, not part of the UK but covered by UK FATCA IGA arrangements.
States of Jersey — Tax Treaties🇮🇲Isle of Manexpand
No US tax treaty. UK treaty in force. Treaty network smaller than Jersey/Guernsey.
Isle of Man Government — Income Tax Division🇵🇦Panamaexpand
No US tax treaty. UK treaty in force. Limited treaty network reflects Panama's historic territorial-tax position.
PwC Worldwide Tax Summaries — Panama🇨🇷Costa Ricaexpand
No US tax treaty despite large US-expat population. Limited treaty network overall.
PwC Worldwide Tax Summaries — Costa Rica🇵🇾Paraguayexpand
Very limited treaty network. No US or UK treaty.
PwC Worldwide Tax Summaries — Paraguay🇰🇾Cayman Islandsexpand
Very few tax treaties (Cayman has 0% domestic CIT and individual income tax). Tax Information Exchange Agreements (TIEAs) with most major economies, but TIEAs are not bilateral tax treaties for treaty-shopping purposes.
Cayman Islands Tax Information Authority🇧🇲Bermudaexpand
Limited treaty network. Bermuda uses Model 2 FATCA IGA. Recent Bermuda CIT Act 2023 (15% CIT on in-scope MNEs from 2025) may drive treaty-network expansion.
PwC Worldwide Tax Summaries — Bermuda🇻🇬British Virgin Islandsexpand
Very limited treaty network. TIEAs are the relevant cross-border information-exchange mechanism, not full income-tax treaties.
BVI International Tax Authority🇦🇮Anguillaexpand
No bilateral income-tax treaties. British Overseas Territory; FATCA via UK-IGA arrangements.
PwC Worldwide Tax Summaries — Anguilla🇧🇸Bahamasexpand
No bilateral income-tax treaties (Bahamas has 0% domestic income tax). FATCA Model 1 IGA in force. TIEAs with most major economies.
PwC Worldwide Tax Summaries — Bahamas🇹🇨Turks and Caicosexpand
No bilateral income-tax treaties. British Overseas Territory.
PwC Worldwide Tax Summaries — Turks & Caicos🇻🇺Vanuatuexpand
No bilateral income-tax treaties. Vanuatu CBI program and 0% income tax mean limited demand for treaty network.
PwC Worldwide Tax Summaries — VanuatuNeed help turning the data into a plan?
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TaxAtlas is research, not tax or legal advice. Treaty interpretation is intricate — actual planning should rely on the treaty text itself (most authorities publish official versions), the OECD Model Tax Convention commentary, and specialist advice. Treaty coverage in this table is binary; the practical rates and benefits depend on the specific articles invoked.