Directors' fees taxable in the company's resident state, permitting source-state taxation of board remuneration abroad. Directors' fees and similar payments received by a resident of one Contracting State for board membership in a company resident of the other Contracting State may be taxed in the State where that company is resident, allocating primary taxing authority over such board remuneration to the source State of the paying company.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Directors' fees taxable in the company's resident state, permitting source-state taxation of board remuneration abroad.
Directors' fees and similar payments received by a resident of one Contracting State for board membership in a company resident of the other Contracting State may be taxed in the State where that company is resident, allocating primary taxing authority over such board remuneration to the source State of the paying company.
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