Directors' fees may be taxed in the state where the employing company is resident when earned by a nonresident director.

Article 16 provides that directors' fees and other similar payments derived by a resident of one Contracting State in his capacity as a member of the board of directors of a company resident in the other Contracting State may be taxed in that other State; the provision allocates taxing rights over board-membership remuneration to the State of the company's residence.

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