Directors' fees: source-state taxation permitted where the company is resident, regardless of fee recipient's residency.

Directors' fees and analogous payments earned by a resident of one Contracting State for service as a member of the board of a company resident in the other Contracting State are subject to taxation in the State where the company is resident, allocating primary taxing rights to that source State over board remuneration paid to nonresident directors under the double tax avoidance framework.

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