Directors' fees may be taxed in the state where the employing company is resident, including top-level managerial pay.

Directors' fees and analogous payments received by a resident of one Contracting State for service on the board of a company resident in the other Contracting State may be taxed in that other State; likewise, salaries, wages and other similar remuneration paid to a resident for holding a top-level managerial office in a company resident in the other State may be taxed in the State where the company is resident.

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