Income Tax Treaties, Agreements, and MLI

Information to assist multinationals apply income tax treaties to cross-border activities and transactions

Manal Corwin

Manal Corwin

Principal in Charge, Washington National Tax, KPMG US

+1 202-533-3127
View more
News and updates from KPMG LLP (KPMG) on U.S. income tax treaties and the Organisation for Economic Co-operation and Development's (OECD's) Multilateral Instrument (MLI)

 

U.S. Tax Treaties

Current Status of U.S. Tax Treaties and International Tax Agreements
September 3, 2021 | This article catalogs the current status of U.S. tax treaties and international tax agreements as of August 27, 2021. | Tax Management International Journal

This article covers:

  • Income tax treaties
  • Estate/gift tax treaties
  • Tax information exchange agreements (TIEAs)
  • FATCA intergovernmental agreements (FATCA IGAs)
  • Reciprocal shipping/aviaiton agreements
  • Social secuirty totalization agreements.

U.S. Income Tax Treaties – Eligibility for Treaty Benefits

The following articles by KPMG Tax professionals were published by Tax Analysts in Tax News International. The articles provide flowcharts to assist practitioners in determining a company's eligibility for treaty benefits under the limitation on benefits provisions of the specific U.S. income tax treaties and, where applicable, in determining eligibility for a 0 percent withholding tax rate on cross-border intercompany dividend payments to the company.

Australia - U.S. Belgium - U.S. Denmark - U.S. Finland - U.S.
France - U.S. Ireland - U.S. Japan - U.S. Mexico - U.S.
New Zealand - U.S. Spain - U.S. Sweden - U.S. Switzerland - U.S.

Treaty news

  • Competent Authority Arrangements on Derivative Benefits under United States-United Kingdom Income Tax Treaty

    KPMG TaxNewsFlash summary and observations | The competent authorities of the United Kingdom and the United States entered into two arrangements regarding the continued inclusion of the United Kingdom, Mexico, and Canada as “equivalent beneficiary” jurisdictions for purposes of applying the so-called “derivative benefits test” in paragraph 3 of Article 23 (Limitation on Benefits) of the United States-United Kingdom income tax treaty.

    August 3, 2021

Treaties & OECD's BEPS Initiative

MAP: Past, Present, and Future
April 12, 2021 | How has OECD's BEPS project changed the way governments handle mutual agreement procedure cases under tax treaties? | Tax Notes International