Directors' fees: the company's residence may tax board remuneration received by nonresident directors. Directors' fees and similar payments received by a resident of one Contracting State for services as a board member of a company resident in the other Contracting State may be taxed in that other State, allocating primary taxing rights to the State where the company is resident under the DTAA framework.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees: the company's residence may tax board remuneration received by nonresident directors.
Directors' fees and similar payments received by a resident of one Contracting State for services as a board member of a company resident in the other Contracting State may be taxed in that other State, allocating primary taxing rights to the State where the company is resident under the DTAA framework.
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