Treaty detail
United States - JM tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1980-05-21
Effective
1982-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 10%
The 10 percent corporate rate generally depends on direct ownership of at least 10 percent of the voting stock of the dividend payer. Jamaican domestic withholding rules interact with the treaty, so article-level review is required.
Interest
Rate: 12.5%
IRS Treaty Table 1 reflects a general 12.5 percent ceiling on qualifying interest, with government and similar carve-outs available subject to article-level review.
Royalties
Rate: 10%
The Jamaica treaty applies a 10 percent royalty ceiling on most categories. Article-level review controls for software, patent, and copyright classification.
Permanent establishment
Construction threshold: more than 183 days
Dependent-agent analysis under the older 1980 wording can be triggered by stock-of-merchandise and agency rules that are narrower than modern OECD-style treaties.
Other treaty flags
Pension treatment is article-specific under the 1980 treaty, with government-service pensions and private pensions handled under distinct provisions. Social Security payments follow separate rules.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to reduced withholding or treaty protection.
Residence under the Jamaica treaty matters for retirees, tourism-sector workers, and U.S.-Jamaican professional families. Tie-breaker rules under the 1980 drafting broadly track OECD-style tests.
Article 5
Permanent Establishment
Sets the business-presence threshold that permits source-country taxation of business profits.
The Jamaica treaty includes shorter construction and supervisory thresholds than many modern U.S. treaties. Dependent-agent analysis remains important under the older treaty wording.
Article 7
Business Profits
Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.
This article matters for U.S. firms in Jamaica's tourism, mining, and offshore services sectors. Article 5 PE analysis must be completed before reliance on Article 7 protection.
Article 10
Dividends
Provides treaty limits on source-country dividend withholding in qualifying cases.
The dividend article's 10 percent and 15 percent ceilings are the quick snapshot, but Jamaican domestic withholding interactions and the article's ownership thresholds control the practical outcome.
Article 11
Interest
Limits source-country withholding on qualifying interest.
The Jamaica treaty does not eliminate interest withholding outright. The 12.5 percent ceiling reflects 1980-era drafting, and government carve-outs may apply subject to article-level review.
Article 12
Royalties
Limits source-country withholding on qualifying royalties.
The royalty article applies a 10 percent ceiling. Software classification under Jamaican law and the article's treatment of mixed payments can affect outcomes for licensing arrangements.
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–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Jamaica treaty documents pageVerified 2026-05-20
- Official U.S.-Jamaica treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
- Treasury treaties in force listVerified 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.