Income Tax Treaty Information

INTERNATIONAL IEEE CONFERENCES – INCOME TAX - current as of 27 February 2008

Although IEEE is exempt from the payment of  "Income Taxes" in the United States on conference net revenue and other exempt purpose revenues, it is not exempt from the payment of income taxes outside the United States. However, if an IEEE conference takes place in a "Tax Treaty Country", in most cases conference revenue will be exempt from income taxes, as explained below. Also be aware that if IEEE conferences take place in "Non-Treaty Countries", conference surpluses or net revenues are subject to local country tax rules, which will probably include income taxes. See additional information below.

I. TAX TREATY COUNTRIES

For conferences that are held outside the United States, but are located in countries that have a bilateral income tax treaty with the U.S., it is the policy of IEEE not to accrue or pay income tax with regard to income earned in those countries. The income tax treaties define when a U.S. corporation is considered doing business in the treaty country, known as a permanent establishment (PE), and those situations and operations that are considered not doing business or PE in the treaty country. Based on the type of activities that IEEE conferences perform in treaty countries, it is the opinion of the IEEE Tax Department that IEEE conferences are not doing business or creating a PE under the rules specified in the income tax treaties with the U.S., and therefore are not subject to the accrual or payment of foreign income taxes on conference revenue.

The countries that have an Income Tax Treaty with the United States are as follows:  Armenia, Australia, Austria, Azerbaijan, Bangladesh, Barbados, Belarus, Belgium, Canada, China, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Georgia, Germany, Greece, Hungary, Iceland, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Kazakhstan, Korea, Kyrgyzstan, Latvia, Lithuania, Luxembourg, Mexico, Moldova, Morocco, Netherlands, New Zealand, Norway, Pakistan, Philippines, Poland, Portugal, Romania, Russia, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Sri Lanka, Switzerland, Tajikistan, Thailand, Trinidad, Tunisia, Turkey, Turkmenistan, Ukraine, United Kingdom, Uzbekistan & Venezuela.

II. NON-TREATY COUNTRIES

IEEE Conferences held in countries that do not have an income tax treaty with the United States must be evaluated on a country-by-country basis as to its taxable status. In general, operations in these countries are subject to tax based on the specific rules of each country's tax regulations. If an IEEE conference is being planned in a non-treaty country, it is recommended that the Chair of the Finance Committee for that conference contact the IEEE Tax Department in order to determine if income taxes should be accrued and paid for that conference.

If you have any questions, please contact the Tax Department at: tax-compliance@ieee.org.