Directors' fees taxation: fees to a resident board member may be taxed in the company's state of residence. Directors' fees and similar payments received by a resident individual for serving as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, establishing source taxation over such board remuneration within the Double Taxation Agreement context.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxation: fees to a resident board member may be taxed in the company's state of residence.
Directors' fees and similar payments received by a resident individual for serving as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, establishing source taxation over such board remuneration within the Double Taxation Agreement context.
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