Directors' fees taxation: payments to nonresident board members may be taxed in the company's residence state. Directors' fees and similar payments received 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 that other State; likewise, salaries, wages and similar remuneration of a resident for service as a top-level managerial official of a company resident in the other Contracting State may be taxed in that other State.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxation: payments to nonresident board members may be taxed in the company's residence state.
Directors' fees and similar payments received 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 that other State; likewise, salaries, wages and similar remuneration of a resident for service as a top-level managerial official of a company resident in the other Contracting State may be taxed in that other State.
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