Directors' fees may be taxed in the state where the company is resident when paid to a foreign director. Directors' fees and similar payments earned by a resident of one Contracting State as a member of the board or analogous organ of a company resident in the other Contracting State may be taxed in that other State, establishing the source-State taxing entitlement over director-related compensation under the DTAA.
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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 earned by a resident of one Contracting State as a member of the board or analogous organ of a company resident in the other Contracting State may be taxed in that other State, establishing the source-State taxing entitlement over director-related compensation under the DTAA.
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