Directors' fees may be taxed in the State where the company is resident, affecting cross-border taxation. Directors' fees 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 that other State, permitting the company resident State to impose tax on such remuneration under the DTAA.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the State where the company is resident, affecting cross-border taxation.
Directors' fees 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 that other State, permitting the company resident State to impose tax on such remuneration under the DTAA.
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