Directors' fees may be taxed by the state where the company is resident, applying source state taxing rights.

Directors' fees and similar payments derived by a resident of one Contracting State in his capacity as a member of the board of a company resident in the other Contracting State may be taxed in that other State, giving the company's State of residence a source taxing right over board remuneration paid to nonresident directors under the double taxation agreement framework.

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