US ETFs for holders outside the US: withholding, treaties and estate tax

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  • As of Oct 30, 2026, the IRS lists 53 treaty countries whose rate on US dividends is 10% to 25%. With no treaty, the US withholds 30% of dividends paid to holders outside the US.

Dividend withholding

A US fund pays its dividends after US tax is withheld. With no treaty the rate is 30% (IRS Publication 515). A tax treaty can set a lower rate for residents of that country. The IRS lists each treaty's rate in Tax Treaty Table 1 (revised May 2023). The treaties with Hungary and Russia no longer reduce it (Publication 515).

Treaty rates by country

Dividend rates in US tax treaties, from IRS Tax Treaty Table 1, read Oct 30, 2026. The portfolio rate applies to most holders; the direct rate applies to a company holding a large stake.
CountryPortfolio rateDirect rate
Armenia30%30%
Australia15%5%
Austria15%5%
Azerbaijan30%30%
Bangladesh15%10%
Barbados15%5%
Belarus30%30%
Belgium15%5%
Bulgaria10%5%
Canada15%5%
Chile15%15%
China, People's Rep of10%10%
Cyprus15%5%
Czech Republic15%5%
Denmark15%5%
Egypt15%5%
Estonia15%5%
Finland15%5%
France15%5%
Georgia30%30%
Germany15%5%
Greece30%30%
Iceland15%5%
India25%15%
Indonesia15%10%
Ireland15%5%
Israel25%12.5%
Italy15%5%
Jamaica15%10%
Japan10%5%
Kazakhstan15%5%
Korea, South15%10%
Kyrgyzstan30%30%
Latvia15%5%
Lithuania15%5%
Luxembourg15%5%
Malta15%5%
Mexico10%5%
Moldova30%30%
Morocco15%10%
Netherlands15%5%
New Zealand15%5%
Norway15%15%
Pakistan30%15%
Philippines25%20%
Poland15%5%
Portugal15%5%
Romania10%10%
Slovak Republic15%5%
Slovenia15%5%
South Africa15%5%
Spain15%5%
Sri Lanka15%15%
Sweden15%5%
Switzerland15%5%
Tajikistan30%30%
Thailand15%10%
Trinidad & Tobago30%30%
Tunisia20%14%
Turkey20%15%
Turkmenistan30%30%
Ukraine15%5%
United Kingdom15%5%
Uzbekistan30%30%
Venezuela15%5%

US estate tax

Stock of US corporations counts as US property for the estate of a person who is neither a US citizen nor a US resident. Such an estate files a US estate tax return when its US property is over $60,000 (IRS, Instructions for Form 706-NA, read Oct 30, 2026). An estate tax treaty can change this.

Distributing or accumulating

US ETFs are distributing funds: a fund taxed as a regulated investment company pays out at least 90% of its taxable income each year (26 U.S.C. 852).

Facts as the IRS publishes them, with the date each was read. Not tax advice.

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ETFIQ, US ETFs for holders outside the US: withholding, treaties and estate tax, data as of Oct 30, 2026. https://etfiq.com/learn/non-us-holders

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Free to use with attribution for ETFIQ’s data. Not investment advice.

Not investment advice. ETFIQ is independent and makes no recommendations.