ARTICLE 27

U.S. Income Tax Treaty — iceland tax treaty documents: iceland.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Investment or Holding Companies

A corporation of one of the Contracting States deriving dividends, interest, royalties, or capital gains from sources within the other Contracting State shall not be entitled to the benefits of Article 12 (Dividends), 13 (Interest), 14 (Royalties), or 16 (Capital Gains) if:

(a) By reason of special measures the tax imposed on such corporation by the firstmentioned Contracting State with respect to such dividends, interest, royalties, or capital gains is substantially less than the tax generally imposed by such Contracting State on corporate profits, and

(b) 25 percent or more of the capital of such corporation is held of record or is otherwise determined, after consultation between the competent authorities of the Contracting States, to be owned directly or indirectly, by one or more persons who are not individual residents of the first-mentioned Contracting State (or, in the case of an Icelandic corporation, who are citizens of the United States).

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▸Contents — U.S. Income Tax Treaty — iceland tax treaty documents: iceland.pdf

U.S. Income Tax Treaty — iceland tax treaty documents: iceland.pdf

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