Treaty detail
United Kingdom - Israel tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1962-09-26
Effective
1963-12-10
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
Following the 2018 protocol, the UK-Israel treaty applies a 5 percent rate for qualifying corporate holdings and 15 percent more broadly, with a zero rate available for certain qualifying pension and government cases.
Interest
Rate: 5%
The 2018 protocol introduced a 5 percent ceiling on interest, with exemptions for qualifying government, bank, and pension cases. The headline rate is the ceiling, and article-level qualifying conditions still apply.
Royalties
Rate: 0%
Following the 2018 protocol, royalties are generally subject to a zero rate under the UK-Israel treaty. The article-level definition controls characterization for mixed contracts.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent rules apply where an agent habitually exercises contract-concluding authority. The 2018 protocol modernized PE-related provisions and incorporated post-BEPS elements.
Other treaty flags
Private pensions are generally taxable only in the residence state under the modernized UK-Israel treaty. Government-service pensions follow a separate rule, and lump sums deserve article-level review.
Seeded article summaries
Article 4
Residence
Defines treaty residence and underpins every other treaty claim.
Residence under the UK-Israel treaty has been modernized by the 2018 protocol. The tiebreaker rules in Article 4 control dual-residence questions and the resulting access to treaty benefits.
Article 5
Permanent Establishment
Defines the threshold for source-country business taxation.
Article 5 was modernized by the 2018 protocol to reflect more contemporary OECD wording. The construction threshold applies to projects exceeding twelve months.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits relief is the practical operating rule for cross-border services and trading between the UK and Israel. Attribution rules apply once a PE exists in the source country.
Article 10
Dividends
Provides reduced treaty rates for qualifying cross-border dividends.
The 2018 protocol substantially modernized the dividend article. Qualifying corporate holdings can benefit from a 5 percent rate, with 15 percent applying more broadly.
Article 11
Interest
Caps source-country withholding on interest at the treaty rate.
Interest payments under the UK-Israel treaty are subject to a 5 percent ceiling following the 2018 protocol. Qualifying government, bank, and pension cases can result in zero withholding.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Following the 2018 protocol, royalties are generally subject to a zero rate under the UK-Israel treaty. The article-level definition governs characterization.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC Israel tax treaties pageVerified 2026-05-20
- Israel Tax Authority international treaties listVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.