News & Insights

The results of the 2024 Tax Treaty Survey are presented below.

#1 Treaty Priority Countries

NFTC member companies who responded to the survey (“respondents”) ranked one country – Brazil – as the clear priority for the most number of respondents. The next tranche of countries were closely clustered together.

• For Brazil, the country identified as most important to respondents, Transfer Pricing was identified as the greatest concern, followed by Mutual Agreement Process (MAP); Business Profits, and Reducing withholding rates on royalties.

The countries identified as next most significant to respondents were: Ireland, Israel, Saudi Arabia, Switzerland, Taiwan, and Malaysia. The negotiation items listed as most significant for each country were:

• Ireland: Business Profits, MAP, and Transfer Pricing were all equally significant.
• Israel: Reducing withholding rates on royalties was most significant, followed by reducing withholding rates on dividends, MAP, and Transfer Pricing.
• Malaysia: Reducing withholding rates on royalties and dividends were both equally significant.
• Saudi Arabia: Business Profits were most significant, followed by Permanent Establishment (PE), MAP, and Transfer Pricing.
• Switzerland: Reducing withholding rates on dividends were most significant, Gains and Interest were also a concern.
• Taiwan: PE, Business Profits, and reducing withholding rates on royalties were all equally significant.

Brazil was also the clear priority for respondents in the 2023 NFTC Tax Treaty Survey. Taiwan, Saudi Arabia, and Switzerland maintain their 2023 position in the next tranche of significant country priorities, while Ireland, Israel, and Malaysia are new additions in 2024. Singapore dropped out of this grouping of the #1 priority, but was still overall relevant to respondents.

Overall Treaty Priority Countries

After evaluating the overall top priority for respondents, we aggregated the results regardless of rank. Atop the list of highest overall priority countries were Brazil, Saudi Arabia, and Singapore. These countries saw the highest combination of overall votes as well as being ranked first or second most important country by respondents. Next was India, in its own tranche, followed by a grouping of Ireland, Israel, Switzerland, and Taiwan. The final tranche featured Argentina, Australia, China, and the UK.

In total, respondents requested treaties with 32 countries.

Items that were selected as most important for these countries were:

• Singapore: Reducing withholding rates on royalties was most significant, followed closely by Business Profits, MAP, and Transfer Pricing.
• India: MAP was most significant, followed by Transfer Pricing. PE, Business Profits, and Limitation on Benefits were also a concern.
• Argentina: Business Profits were most significant, followed by reducing withholding rates on royalties, MAP, and Transfer pricing.
• China: Reducing withholding rates on royalties was most significant, with MAP, Transfer Pricing, and Covered Taxes also a concern.
• UK: MAP and Transfer Pricing were most significant, with Business Profits and reducing withholding rates on royalties also a concern.

Compared to 2023 results, Brazil and Singapore maintained their position as top overall priority countries, with Saudi Arabia replacing Taiwan in the top tranche. India remains in its own tranche. The third and fourth tranches shuffled more notably. Hungary, Colombia, and Mexico are out, while Argentina and China are in. The UK maintained its 2023 position in the final tranche.

An infographic of the most requested countries can be found here.