Withholding tax rates on cross‑border payments vary substantially across jurisdictions and across types of income. In 2026, the average statutory withholding tax rate across the 146 jurisdictions covered was 12.2% for dividends, 12.8% for interest, and 14.5% for royalties, all well below average statutory corporate income tax rates.
High statutory withholding tax rates remain relatively common for all three payment types. Twelve jurisdictions applied dividend withholding tax rates of 30% or more, while ten jurisdictions applied interest withholding tax rates at or above 30% and eleven jurisdictions applied royalty withholding tax rates of at least 30% in 2026.
At the opposite end of the distribution, a substantial number of jurisdictions apply zero statutory withholding tax rates. In 2026, 37 jurisdictions applied a zero rate on dividends, 34 on interest, and 27 on royalties.
Tax treaties substantially reduce withholding tax burdens relative to domestic law. Treaty‑based withholding tax rates are significantly lower across all payment types, underscoring the central role of bilateral tax conventions in limiting source‑based taxation and shaping effective cross‑border tax outcomes.
Treaty‑based withholding tax rates on technical fees are particularly low. Over 80% of bilateral treaties apply a rate below 5%, reflecting widespread treaty practices that restrict source‑based taxation of services income, especially in the absence of a permanent establishment in the source jurisdiction.
The global network of bilateral tax treaties has expanded markedly over recent decades, increasing from 1 063 treaties in 1990 to over 5 300 treaties in 2026. However, growth in the number of treaties has slowed in recent years, with only 454 additional treaties concluded between 2017 and 2026.
Treaty coverage differs significantly across regions. OECD member countries maintain far denser treaty networks, averaging around 70 treaties per jurisdiction in 2026, compared with fewer than 20 treaties on average in Africa and in Latin America and the Caribbean, with growth in treaty coverage since 1990 strongest among OECD countries.
Corporate Tax Statistics 2026
Withholding taxes (WHTs) are levied on businesses when they make payments to other foreign or domestic business entities or individuals, e.g., in the form of dividends, interest, and royalties. Governments collect these taxes based on statutory or preferential treaty-based tax rates requiring businesses to withhold a fraction of cross-border payments in scope of the WHT. Data on withholding taxes can be used to improve understanding of multinational enterprise (MNE) decisions about investment, repatriation, finance and organisational structures among other tax policy issues. income taxes levied on profits.
Bilateral tax conventions form a central component of the international tax framework by allocating taxing rights between contracting jurisdictions and reducing instances of juridical double taxation. By limiting the extent of source‑based taxation on cross‑border income flows and by providing greater legal certainty for taxpayers, tax treaties can facilitate international trade, services and investment. In particular, treaty provisions governing withholding taxes establish agreed ceilings on the taxation of certain categories of income, thereby constraining excessive or discriminatory source taxation.
Data on WHT rates support analysis of multinational enterprise (MNE) investment, financing and profit repatriation decisions, as well as broader tax policy considerations. Differences in WHT rates across jurisdictions and across types of payments may influence the cost of capital, the allocation of debt and intangible assets, and the structure of cross-border investments. WHT data can also provide insights into certain base erosion and profit shifting (BEPS) strategies, including treaty shopping. The publication of WHT rates in Corporate Tax Statistics was envisaged in the 2015 BEPS Action 11 Report (OECD, 2015[1]).
The Corporate Tax Statistics database reports standard and treaty based WHTs for resident corporations on:
dividends;
interest;
royalties;
technical fees
The data presented in this chapter cover WHTs for all members of the Inclusive Framework (IF) on base erosion and profit shifting (BEPS). Comparisons are also made with the averages of the 38 OECD economies, of the 27 LAC jurisdictions (four of which are also OECD members), of 36 African jurisdictions and of 36 Asia and Pacific jurisdictions (four of which are also OECD members) as well as income groups.1
Standard withholding tax rates
The average statutory withholding tax rate on dividend payments across the 146 jurisdictions covered in this edition was 12.2%. Dividend WHT rates display considerable variation across members of the Inclusive Framework in 2026 (Figure 3.1). Of the jurisdictions covered, 12 applied dividend withholding tax rates of 30% or above. At the other end of the distribution, 37 jurisdictions applied a zero rate on dividend payments, reflecting either the absence of a dividend withholding tax or the application of a full exemption. A further 14 jurisdictions applied positive dividend WHT rates below 10%, indicating relatively low taxation of cross-border dividends.
The average statutory withholding tax rate on interest payments was slightly higher, at 12.8% across the 146 jurisdictions covered. Interest WHT rates also vary widely among Inclusive Framework members. Ten jurisdictions applied interest withholding tax rates of 30% or above in 2026. In contrast, 34 jurisdictions imposed a zero-withholding tax on interest payments, while six jurisdictions applied positive interest WHT rates below 10%, suggesting a significant group of economies with either exempt or lightly taxed cross‑border interest payments.
Withholding tax rates on royalty payments are, on average, higher than those applied to dividends and interest. Across the 146 jurisdictions covered, the average statutory royalty withholding tax rate was 14.5%. Royalty WHT rates also show substantial dispersion. Eleven jurisdictions applied royalty withholding tax rates of 30% or more, while 27 jurisdictions applied a zero rate on royalty payments. At the lower end of the positive rate distribution, only four jurisdictions applied royalty withholding tax rates below 10%, indicating that royalty payments are more frequently subject to moderate or high source‑based taxation.
The average statutory withholding tax rates on cross‑border payments vary across income groups in 2026 (Figure 3.2). For dividends, high‑income jurisdictions applied the highest average rate (15.9%), followed by low‑income (13.9%) and middle‑income jurisdictions (11.5%), while investment hubs applied much lower rates (5.2%). A different pattern emerges for interest payments, where low‑income (16.4%) and middle‑income jurisdictions (15.1%) applied higher average rates than high‑income jurisdictions (13.3%), with investment hubs again applying very low rates (4.3%).
Withholding taxes on royalties and technical service fees are generally higher, especially in lower‑income economies. Low‑income jurisdictions recorded the highest average rates on royalties (20.0%) and technical fees (21.2%), followed by middle‑income and high‑income jurisdictions at progressively lower levels. In contrast, investment hubs consistently applied very low rates across both categories, at 2.8% for royalties and 2.6% for technical fees.
Treaty based withholding tax rates
Note: Data are based on bilateral treaties reported by all IF member jurisdictions. The database refers to bilateral tax treaties only. Multilateral agreements are not accounted for. Other tax-related agreements such as tax information exchange agreements are not counted. Only treaties in effect are counted. For each of the categories of payment flows, existing treaties that do not specify the applicable withholding tax rate, and hence create missing values, are not included in this figure. Where a tax treaty provides for different rates for specified ownership percentages, this entry reflects the highest ownership percentage.
The global network of bilateral tax treaties has expanded substantially over recent decades. Among the 146 jurisdictions covered in the dataset, the number of treaties increased from 1 063 in 1990 to over 5 300 in 2026 (Figure 3.4). This expansion reflects the continued importance attached by jurisdictions to bilateral tax conventions as instruments for allocating taxing rights, reducing double taxation and providing certainty for cross‑border economic activity.
More recent years, however, have been characterised by a moderation in the pace of treaty network expansion. Between 2017 and 2026, only 454 additional treaties were incorporated into the database, indicating a relative levelling‑off compared with earlier periods of rapid growth (Figure 3.4). This slower increase in the number of new treaties does not imply an absence of treaty‑related developments. Rather, it reflects, in part, a shift from the conclusion of new bilateral agreements towards the modification of existing treaties, including through the widespread adoption of the Multilateral Instrument (MLI) and the negotiation of bilateral protocols amending pre‑existing conventions.
Note: Data are based on bilateral treaties reported by all IF member jurisdictions and one non-IF jurisdiction. The database refers to bilateral tax treaties only. Multilateral agreements are not accounted for. Other tax-related agreements such as tax information exchange agreements are not counted. Only treaties in effect are counted.
Source: OECD Bilateral Tax Treaties Database.
Treaty coverage continues to vary significantly across groups of jurisdictions. As shown in Figure 3.5, OECD countries maintain substantially larger treaty networks on average than jurisdictions in Africa and in LAC. In 2026, OECD members averaged around 70 treaties per jurisdiction, compared with fewer than 20 treaties on average in Africa and around 22 in LAC jurisdictions. Although all regional groupings have experienced sustained growth in their average number of tax treaties over time, the expansion has been most pronounced among OECD countries, further widening differences in treaty network density across regions.
Treaty coverage also differs markedly across income groups. As illustrated in Figure 3.6, high‑income jurisdictions maintain considerably denser treaty networks on average than other groups. In 2026, high‑income jurisdictions averaged just under 54 treaties per jurisdiction, compared with around 31 among middle‑income jurisdictions and fewer than 5 among low‑income jurisdictions. Investment hubs show evidence of extensive treaty networks with almost 40 treaties per jurisdiction in 2026.
Note: Data are based on bilateral treaties reported by all IF member jurisdictions. The database refers to bilateral tax treaties only. Multilateral agreements are not accounted for. Other tax-related agreements such as tax information exchange agreements are not counted. Only treaties in effect are counted.
Taken together, these trends underline both the maturity of the global tax treaty network and the evolving nature of treaty activity. While the overall number of treaties continues to increase, recent developments have focused increasingly on updating and adapting existing agreements rather than on the negotiation of entirely new conventions. The data also confirm that treaty‑based withholding tax rates are, on average, substantially lower than rates applicable under domestic law, highlighting the continued central role of tax treaties in limiting source‑based taxation on cross‑border income and shaping effective withholding tax outcomes.
References
[2] Auerbach, A., M. Devereux and H. Simpson (2008), “Taxing corporate income”, https://www.nber.org/papers/w14494 (accessed on 18 February 2023).
[1] OECD (2015), Measuring and Monitoring BEPS, Action 11 - 2015 Final Report, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/9789264241343-en.
← 1. Jurisdiction groups (high-, middle- and low-income) are based on the latest World Bank classifications. Investment hubs are defined as jurisdictions with an average total inward Foreign Direct Investment (FDI) position above 150% of gross domestic product (GDP) across the latest 3 years for which data is available.