Directors' fees may be taxed in the state where the company is resident when paid to a foreign director. Directors' fees and similar payments received by a resident of one Contracting State as a member of the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating source-state taxing rights over remuneration for board membership under the Double Taxation Avoidance Agreement.
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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 when paid to a foreign director.
Directors' fees and similar payments received by a resident of one Contracting State as a member of the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating source-state taxing rights over remuneration for board membership under the Double Taxation Avoidance Agreement.
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