Directors' fees may be taxed in the state where the company of which the director is a member is resident.

Directors' fees and similar payments paid to a resident of one Contracting State for service as a member of the board of directors of a company resident in the other Contracting State are subject to taxation in the State where the company is resident, allocating primary taxing rights over remuneration for board service to the source State within the double taxation avoidance framework.

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