Treaty detail
United States - TN tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1985-06-17
Effective
1990-02-26
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 20% · Corporate rate: 14%
The 14 percent corporate rate generally depends on direct ownership of at least 25 percent of the capital of the dividend payer. Tunisian domestic withholding interactions can affect the practical outcome, so article-level review is essential.
Interest
Rate: 15%
IRS Treaty Table 1 reflects a general 15 percent ceiling on qualifying interest, with reduced 10 percent rates available for certain bank loans of three years or more. Government and similar carve-outs may apply.
Royalties
Rate: 15%
The Tunisia treaty applies a relatively high 15 percent royalty ceiling on most categories, with reduced rates available for certain copyright royalties. Software and know-how classification can affect outcomes.
Permanent establishment
Construction threshold: more than 183 days
Dependent-agent analysis under the 1985 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 1985 treaty, with government-service pensions and private pensions handled under distinct provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to reduced withholding or treaty protection.
Residence under the Tunisia treaty matters for U.S. consultants and firms with Tunisian project work. Tie-breaker rules under the 1985 drafting broadly track OECD-style tests.
Article 5
Permanent Establishment
Sets the business-presence threshold that permits source-country taxation of business profits.
The Tunisia treaty includes shorter construction and supervisory thresholds than many modern U.S. treaties. Service-PE and dependent-agent analysis remain 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 operating in Tunisian manufacturing, tourism, and energy 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 14 percent and 20 percent ceilings are higher than many modern U.S. treaties. Tunisian domestic withholding interactions and the article's ownership thresholds control the practical outcome.
Article 11
Interest
Limits source-country withholding on qualifying interest.
The Tunisia treaty does not eliminate interest withholding outright. The 10-15 percent rate range and the bank-loan carve-out require careful documentation and beneficial-ownership analysis.
Article 12
Royalties
Limits source-country withholding on qualifying royalties.
The royalty article applies a 15 percent ceiling on most categories, with reduced rates for certain copyright royalties. Article-level classification controls the outcome for software 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–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Tunisia treaty documents pageVerified 2026-05-20
- Official U.S.-Tunisia 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.