Does Guatemala have double-taxation treaties, and can withholding be reduced under a treaty?

No. Guatemala has no double-taxation treaty in force (PwC, reviewed Jun 9, 2026). It signed a treaty with Mexico in 2015 that Congress has not ratified; secondary reports (CIAT, IMF 2023) mention as many as 7 bilateral agreements signed and awaiting ratification. Guatemala is a signatory of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters - information exchange, not relief from double taxation. The implication: the Article 104 withholdings (5%/10%/15%/25%) are final and cannot be reduced by treaty; relief depends on a unilateral foreign tax credit in the investor's country of residence.