W-8BEN-E for a Greek IKE: the 1950 treaty does not cut US dividends
This article was created with AI assistance and has not been reviewed by a human editor. It is provided for general informational purposes only and does not constitute tax, legal, or financial advice.
Treaty articles and rates on this page are checked against the US-Greece income tax convention signed at Athens on February 20, 1950, and the Protocol signed April 20, 1953 (irs.gov/pub/irs-trty/greece.pdf) — last verified September 2026. Ratifications were exchanged on December 30, 1953. The convention is effective from January 1, 1953. The official text numbers articles with Roman numerals. This page cites the Arabic numbers that go on the form.
AI-generated imageMany guides quote a 15% treaty rate for Greece. There isn't one. Dividends paid by US companies to Greek residents are withheld at the statutory 30%. The convention does not give a reduced rate for those dividends.
This guide is for a Greek Idiotiki Kefalaiouchiki Etaireia (IKE) or an Anonymi Etaireia (AE) that invoices US clients. It covers which income is exempt, why the form uses Article 3, Article 6, Article 7, and Article 10 instead of Roman numerals, why Line 14b is No LOB article in treaty, and which number goes on Line 9b. A sample PDF is included further down.
If you are a self-employed person (atomiki epicheirisi), you file Form W-8BEN, not this one: start the W-8BEN wizard. Personal services are Article X in the convention and Article 10 on the form. Do not cite Article 14. A resident of Greece is exempt only if present in the United States for no more than 183 days in the taxable year and either the services are under contract with a Greek resident or Greek corporation, or the compensation does not exceed $10,000. Services performed entirely in Greece are foreign-source and are not US withholding in the first place. The AFM on that form is the same 9-digit number a company uses.
When the income is industrial or commercial profits and the company has no US permanent establishment, you can start the W-8BEN-E wizard now. In a few minutes you have a signature-ready PDF for $30, with Article 3 at 0% and Line 14b set to No LOB article in treaty.
Blank form or already filled in?
You can download the official, blank form from the IRS and complete it yourself — or get the same file already filled in by our wizard.
- Blank official W-8BEN-E (IRS, free): Download W-8BEN-E as a PDF directly from the IRS — for an IKE, an EPE, or an AE.
- Blank official W-8BEN (IRS, free): Download W-8BEN as a PDF directly from the IRS — for a self-employed individual.
- Already filled in (5–10 minutes): W-8BEN-E for Greek companies ($30) or W-8BEN for individuals ($5).
- The convention: US-Greece Income Tax Treaty PDF on IRS.gov — signed February 20, 1950. Article III is industrial or commercial profits. There is no Limitation on Benefits article.
IKE, EPE, or AE?
Greek company law uses more than one limited company, and US tax classification does not follow the local label one-for-one:
- Anonymi Etaireia (AE / Α.Ε.): 26 CFR 301.7701-2(b)(8)(i) lists "Greece, Anonymos Etairia" as a per se corporation. It is a Corporation and cannot file Form 8832.
- Idiotiki Kefalaiouchiki Etaireia (IKE / ΙΚΕ): The usual private company. It is not on the per se list. It defaults to Corporation because its members have limited liability, and a different US classification is made on Form 8832. A single-member IKE is not disregarded by default.
- Etaireia Periorismenis Efthynis (EPE / ΕΠΕ): Also not on the per se list. It defaults to Corporation for the same reason, and Form 8832 is how a different US classification is made.
- Omorrythmi or Eterorrythmi Etaireia (OE / EE): Defaults to Partnership when at least one partner has unlimited liability, under 26 CFR 301.7701-3(b)(2). Check Partnership in Part I, line 4, not Corporation.
- Atomiki epicheirisi: Not a company. That person files Form W-8BEN and cites Article 10, not Article 14.
The trap worth naming: an IKE is not the AE on the per se list. It defaults to Corporation and can leave that default on Form 8832. The treaty question is separate. Even a correctly classified Corporation writes Arabic article numbers, not the Roman numerals printed in the 1950 text.
Chapter 3 still decides which form you file. Part III is where the article and the rate go, and Line 14b for this treaty is the box that says the treaty has no Limitation on Benefits article.
Who actually needs to submit this form?
Any Greek IKE, EPE, or AE that receives payments from a US business and needs to document that it is not a US person. What you claim in Part III depends on the income:
- Services with no US permanent establishment: Article III in the convention, written as Article 3 on the form, at 0%. Industrial or commercial profits of a Greek enterprise are not taxed by the United States unless the enterprise carries on business there through a permanent establishment.
- A US dividend: No treaty article and no reduced rate. The statutory 30% applies. Article IX is about dividends and interest paid by a Greek corporation. It does not cut a dividend from a US company. A W-8BEN-E is still the form that tells the payer you are foreign, which matters for backup withholding, but it will not turn 30% into 15%.
- A software licence, not a film: Royalties for copyrights, patents, designs, secret processes, trademarks, and know-how, and rentals of industrial, commercial, or scientific equipment, are Article VII, written as Article 7, at 0%. Royalties for motion picture films are excluded and stay at 30%.
Roman numerals on the form, and no LOB article
The official text says Article III, Article VI, Article VII, and Article X. Form W-8BEN and Form W-8BEN-E ask for an Arabic article number. Write Article 3 for industrial or commercial profits, Article 6 for interest, Article 7 for the royalties that the convention exempts, and Article 10 for an individual's personal services. Do not write III, VI, VII, or X in the article box.
The 1950 convention has no Limitation on Benefits article. Line 14b is the checkbox "No LOB article in treaty". Do not certify active trade or business, ownership and base erosion, or publicly traded. Those tests are not in this treaty.
| Step | Result |
|---|---|
| 1. Company services, no US permanent establishment | Article 3 (III in the text), 0%. |
| 2. Interest from an unrelated US debtor | Article 6 (VI), 0%, unless a Greek company controls more than 50% of the voting power of the US payer. |
| 3. Software, patents, trademarks, know-how, equipment rental | Article 7 (VII), 0%. |
| 4. Motion picture film royalties | No exemption. Statutory 30%. |
| 5. Dividends from a US company | No article and no reduced rate. Statutory 30%. |
| 6. Line 14b | No LOB article in treaty. |
Why this treaty is still the 1950 text
This is the oldest US income tax treaty in this product. It was signed at Athens on February 20, 1950. A protocol signed April 20, 1953 limits mutual assistance in collection. It does not add a dividend rate. Ratifications were exchanged on December 30, 1953, and the convention is effective from January 1, 1953. No later convention has replaced it as of 2026. Do not import a 5% or 15% dividend rate from a modern treaty.
Line by line for an operating IKE
| Line | What you enter |
|---|---|
| Line 1 | The legal name, for example Aegean IKE. |
| Line 2 | Greece. |
| Line 4 | Corporation for an IKE, an EPE, or an AE. Partnership for an OE or EE. A self-employed individual files Form W-8BEN. |
| Line 6 | The registered office in Latin letters (e.g., Panepistimiou 20, Athens, 106 71). |
| Line 9b | The AFM (ΑΦΜ), 9 digits, for example 123456783. The same format is used for a company and for a person. 123456789 fails the check digit. Do not enter a ΓΕΜΗ (GEMI) number. Do not add EL unless the payer asked for a VAT ID. |
| Line 14a | Greece, when you are claiming the treaty for income the convention actually covers. |
| Line 14b | No LOB article in treaty. Do not check active trade or business, ownership and base erosion, or publicly traded. |
| Line 15 | For services with no US permanent establishment: Article 3, 0%, type of income industrial or commercial profits. Do not write III. Interest from an unrelated US debtor is Article 6 at 0%. A software licence is Article 7 at 0%. A US dividend has no article and no rate on this line. |
Read the AFM from the tax record before Line 9b. The company registry number at ΓΕΜΗ is not the TIN. EL followed by the AFM is the VAT number.
The guided W-8BEN-E wizard writes Arabic article numbers and sets Line 14b to No LOB article in treaty.
Filled example: Aegean IKE
An operating IKE with no US permanent establishment. Chapter 3 Corporation, FATCA Active NFFE, Part III Article 3 at 0% for industrial or commercial profits, Line 14b No LOB article in treaty, AFM 123456783.
Sample only — uses a fictional company for illustration. Example: Aegean IKE, Panepistimiou 20, Athens 106 71, Greece, AFM 123456783, Chapter 3 Corporation, FATCA Active NFFE, Article 3 at 0%, Line 14b No LOB article in treaty. A US dividend would not use this Part III rate.
What is exempt, and what stays at 30%
Use Arabic numbers on the form. The Roman numeral is the same article in the 1950 text.
| Income type | Article | Rate |
|---|---|---|
| Services of a company, no US permanent establishment | Article 3 | 0% |
| Interest, unless the Greek company controls more than 50% of the US payer | Article 6 | 0% |
| Software, patents, trademarks, know-how, and equipment rental | Article 7 | 0% |
| Motion picture film royalties | No article | 30% |
| Dividends paid by a US company | No article | 30% |
| Personal services of an individual (Form W-8BEN) | Article 10 | 0% only if no more than 183 days and either a Greek contract or no more than $10,000 |
Article 6 is 0% for US-source interest received by a Greek resident or corporation with no US permanent establishment, except interest paid by a US corporation to a Greek corporation that controls, directly or indirectly, more than 50% of the voting power of the payer. That related-party interest has no treaty exemption. Article 7 does not cover motion picture films. Article 9 in the convention is about Greek-source dividends and interest. It is not a rate for a dividend from a US company. An individual cites Article 10 only when the 183-day test and either the Greek-contract test or the $10,000 cap are met. Remote services performed in Greece are foreign-source before any treaty claim.
Questions people ask before they sign
Short answers for an IKE. A US office, a fund, or a financial institution needs an accountant, not a blog page.
Why does my broker withhold 30% on dividends if Greece has a treaty?
Because this treaty does not reduce dividends paid by US companies. The statutory 30% applies. Article IX covers dividends and interest paid by a Greek corporation. A form still documents foreign status, which can matter for backup withholding, but it does not create a 15% or 5% rate.
Which article for services — 7 or III?
For a company, Article III, written as Article 3. Do not write the Roman numeral, and do not cite Article 7 for services. On this form Article 7 is the royalty article (VII in the text), not a modern Business Profits article.
Are film royalties exempt?
No. Royalties in respect of motion picture films are excluded from Article VII and stay at the statutory 30%. A software copyright, a patent, a trademark, know-how, and equipment rental can be Article 7 at 0%.
Is a new treaty coming?
No later convention has replaced the 1950 text as of 2026. The 1953 protocol limits collection assistance. It does not add a dividend rate.
I'm a freelancer in Greece — which article?
Article 10, on Form W-8BEN. That is Article X in the convention. It covers labor and personal services, including the liberal and artistic professions. Exemption needs no more than 183 days in the United States and either a contract with a Greek resident or Greek corporation, or compensation of no more than $10,000. Do not cite Article 14.
Which number goes on Line 9b?
The AFM, 9 digits, for example 123456783. The same format is used for a company and for a person. 123456789 fails the check digit. ΓΕΜΗ (GEMI) is the registry, not the TIN. EL plus the AFM is the VAT number. Do not type the EL prefix unless the payer asked for a VAT ID.
Can an IKE file Form 8832?
Yes, when it needs a US classification other than Corporation. An AE is per se under "Greece, Anonymos Etairia" and cannot file Form 8832. An IKE and an EPE are not on that list. They default to Corporation, and Form 8832 is how they elect a different classification. A single-member IKE is not disregarded by default.
What if the Greek company owns the US payer?
Interest paid by a US corporation to a Greek corporation that controls, directly or indirectly, more than 50% of the voting power of the payer has no treaty exemption. Ordinary interest from an unrelated debtor can be Article 6 at 0% when there is no US permanent establishment.
What to do next
- Fill out your W-8BEN-E in the guided wizard: Start the W-8BEN-E wizard ($30). It cites Article 3 for services and sets Line 14b to No LOB article in treaty.
- Are you self-employed?: Use the W-8BEN wizard ($5) and cite Article 10, not Article 14.
Mistakes that get the form sent back
- Writing 15% on a US dividend: This treaty has no reduced rate for dividends paid by US companies. The statutory rate is 30%.
- Citing Article 7 for company services: Services are Article 3. Article 7 on the form is royalties. The convention prints those as III and VII.
- Citing Article 14 for a freelancer: An individual cites Article 10 on Form W-8BEN. That is Article X.
- Picking an LOB test: There is no Limitation on Benefits article. Line 14b is No LOB article in treaty.
- Typing an invalid AFM: Line 9b takes 9 digits that pass the check digit, for example 123456783. 123456789 fails. ΓΕΜΗ is not the TIN, and EL is the VAT prefix.