Directors' fees may be taxed in the state where the company is resident when paid to a resident of the other state. Article 15 allocates taxing rights over directors' fees and similar payments: remuneration derived 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 the State where that company is resident.
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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 resident of the other state.
Article 15 allocates taxing rights over directors' fees and similar payments: remuneration derived 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 the State where that company is resident.
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