Directors' fees may be taxed in the state where the company is resident under the tax treaty allocation of taxing rights. Article 17 provides that directors' fees and similar payments derived by a resident of one Contracting State in his capacity as a board member of a company resident in the other Contracting State may be taxed in that other State, thereby allocating taxing rights over board remuneration to the State of the company's residence under the treaty.
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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 the tax treaty allocation of taxing rights.
Article 17 provides that directors' fees and similar payments derived by a resident of one Contracting State in his capacity as a board member of a company resident in the other Contracting State may be taxed in that other State, thereby allocating taxing rights over board remuneration to the State of the company's residence under the treaty.
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