Directors' fees may be taxed in the state where the company is resident under source-based treaty rules. Directors' fees and analogous payments paid to a resident of one Contracting State for service as a member of the board or similar organ of a company resident in the other Contracting State may be taxed in the State where that company is resident, allocating a source-based taxing right to the State of the enterprise within the treaty framework.
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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 under source-based treaty rules.
Directors' fees and analogous payments paid to a resident of one Contracting State for service as a member of the board or similar organ of a company resident in the other Contracting State may be taxed in the State where that company is resident, allocating a source-based taxing right to the State of the enterprise within the treaty framework.
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