Treaty detail
United Kingdom - Mexico tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1994-02-02
Effective
1994-12-15
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
Following the 2009 protocol, qualifying corporate holdings can benefit from a zero-percent rate under the UK-Mexico treaty. The 15 percent rate applies more broadly, with article-level qualifying conditions.
Interest
Rate: 10%
Interest is generally subject to a 10 percent ceiling. The 2009 protocol introduced specific exemptions for qualifying government, bank, and pension cases that can result in a 5 percent or zero rate.
Royalties
Rate: 10%
Royalties are generally subject to a 10 percent ceiling under the UK-Mexico treaty. The article-level definition includes copyright, patent, and know-how, with characterization governed by the article text.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent rules apply where an agent habitually exercises contract-concluding authority. The UK-Mexico treaty includes a service PE concept that triggers when services are rendered for more than six months in any twelve-month period.
Other treaty flags
The UK-Mexico treaty divides pension rights between source and residence. Government-service pensions generally follow source-country rules, with private pensions following residence.
Seeded article summaries
Article 4
Residence
Defines treaty residence and underpins every other treaty claim.
Residence under the UK-Mexico treaty controls access to reduced rates and PE-based protections. Dual-residence questions are resolved using tiebreaker rules in Article 4.
Article 5
Permanent Establishment
Defines the threshold for source-country business taxation.
Article 5 follows the OECD pattern with a six-month construction threshold, reflecting the more developing-economy-oriented baseline often used in Mexican treaties.
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 Mexico. Attribution rules apply once a PE exists.
Article 10
Dividends
Provides reduced and zero-percent rates for qualifying cross-border dividends.
The 2009 protocol substantially modernized the dividend article. Qualifying corporate holdings can achieve a zero rate, with 15 percent applying more broadly.
Article 11
Interest
Caps source-country withholding on interest at the treaty rate.
Interest payments between the UK and Mexico are subject to a 10 percent ceiling under the treaty, with protocol-based exemptions for qualifying recipients.
Article 12
Royalties
Caps source-country withholding on royalties at the treaty rate.
Royalties are subject to a 10 percent ceiling. The article-level definition governs characterization for software, IP, and know-how payments.
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
- TreatyUS–MX treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
Primary sources
- HMRC Mexico tax treaties pageVerified 2026-05-20
- Mexican SAT international tax 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.