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Directors' fees may be taxed in the state where the company is resident when paid to a non-resident director. Directors' fees and similar payments 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 the State where that company is resident, allocating primary taxing entitlement over such board remuneration to the company's State of residence under the treaty.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
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 non-resident director.
Directors' fees and similar payments 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 the State where that company is resident, allocating primary taxing entitlement over such board remuneration to the company's State of residence under the treaty.
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