Directors' fees taxation may be imposed by the state where the company is resident under treaty rules. Directors' fees and other similar payments derived by a resident of one Contracting State in his capacity as a member of the board of a company resident in the other Contracting State may be taxed in that other State; the rule allocates taxing power over board-member 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 taxation may be imposed by the state where the company is resident under treaty rules.
Directors' fees and other similar payments derived by a resident of one Contracting State in his capacity as a member of the board of a company resident in the other Contracting State may be taxed in that other State; the rule allocates taxing power over board-member remuneration to the State of the company's residence under the treaty.
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