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United States - Greece tax treaty

A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.

Signed

1950-02-20

Effective

1953-12-30

Articles seeded

6

Withholding snapshot

Dividends

Individual rate: 30% · Corporate rate: 30%

The 1950 Greece treaty is the oldest U.S. tax treaty still in force and does not include the modernized dividend-reduction framework found in later treaties. As a result, statutory 30 percent withholding generally applies to dividends and analysis should focus on whether other treaty articles provide relief.

Interest

Rate: 0%

The 1950 treaty generally provides zero-percent source-country interest withholding for qualifying categories. Beneficial-ownership and qualifying-status conditions remain subject to article-level review.

Royalties

Rate: 0%

The 1950 treaty generally provides zero-percent source-country withholding for qualifying royalty categories, though the definitions reflect mid-twentieth-century treaty drafting and deserve careful article-level review.

Permanent establishment

Construction threshold: not specified under modern OECD wording in the 1950 treaty

Dependent-agent analysis under the 1950 wording remains important and should be applied with reference to the older treaty text.

Other treaty flags

Pensions: residence
Protocols: None seeded
Exchange of information: Yes
Student article: Yes
Teacher article: Yes

The 1950 Greece treaty allocates pensions in a manner that pre-dates modern U.S. treaty practice. Practical results may differ from newer treaties and deserve article-level review.

Seeded article summaries

Article 4

Residence

Defines treaty residence under the 1950 treaty framework.

The Greece treaty predates virtually all modern U.S. tax treaty drafting. The residence article must be applied with care because it does not include modern tie-breaker or limitation-on-benefits language.

Article 5

Permanent Establishment

Sets the business-presence threshold for source-country taxation under the 1950 framework.

The 1950 Greece treaty uses older PE definitions that should be confirmed against the current treaty text. Modern OECD construction-and-installation thresholds may not apply directly under this older framework.

Article 7

Business Profits

Generally reserves business profits to the residence state absent a permanent establishment in the other state.

This is the operating-rule article once the PE analysis is complete. Under the 1950 framework, the analysis is more textually constrained than in newer treaties and requires careful article-level review.

Article 10

Dividends

Does not provide a reduced source-country withholding rate for dividends.

The 1950 Greece treaty is notable for not providing the dividend-rate reduction common in newer U.S. treaties. As a result, the statutory 30 percent U.S. withholding rate generally applies to U.S.-source dividends paid to Greek residents.

Article 11

Interest

Generally eliminates source-country withholding on qualifying interest.

Interest under the 1950 Greece treaty is generally not subject to source-country withholding for qualifying categories. Article-level review is especially important given the age of the treaty.

Article 12

Royalties

Generally removes source-country withholding on qualifying royalties.

The royalty article under the 1950 Greece treaty generally produces a zero-percent result for qualifying categories, but the definitions reflect mid-twentieth-century treaty drafting and deserve careful article-level review.

Official text

Other treaties involving these jurisdictions

Computed from the cross-reference graph. Links open the related entity on this site.

Primary sources

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.