FAQ
What is a treaty saving clause?
How the saving clause can preserve a country’s right to tax its citizens and residents despite other treaty articles.
A saving clause generally preserves a country’s ability to tax its citizens or residents as if the treaty had not entered into force, subject to listed exceptions. For U.S. citizens abroad, this is why a residence-country treaty article does not automatically erase U.S. tax. Read the specific treaty and protocol for the income category at issue.