Taxation of directors' fees permits source state taxation of fees paid to foreign resident board members under the treaty. Article 16 allocates taxing rights by providing that directors' fees and similar payments received by 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.
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Provisions expressly mentioned in the judgment/order text.
Taxation of directors' fees permits source state taxation of fees paid to foreign resident board members under the treaty.
Article 16 allocates taxing rights by providing that directors' fees and similar payments received by 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.
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