Directors' fees: taxable in the state where the company is resident under cross-border tax treaty rules.

Directors' fees and similar payments paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident; the provision allocates the primary taxing right over remuneration for board services to the State of the company's residence under the double tax avoidance agreement.

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