Directors' fees may be taxed in the state where the company is resident when paid to a nonresident director. Directors' fees 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, treating remuneration for board service as subject to source-state taxation when paid to nonresident directors.
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 may be taxed in the state where the company is resident when paid to a nonresident director.
Directors' fees 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, treating remuneration for board service as subject to source-state taxation when paid to nonresident directors.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.