Directors' fees taxability: fees paid to a nonresident director may be taxed in the company's state of residence. Directors' fees paid in a director's capacity are subject to taxation in the Contracting State where the company is resident; a resident of one Contracting State receiving such fees from a company resident in the other Contracting State may be taxed by the company's State of residence on those fees and similar payments.
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 taxability: fees paid to a nonresident director may be taxed in the company's state of residence.
Directors' fees paid in a director's capacity are subject to taxation in the Contracting State where the company is resident; a resident of one Contracting State receiving such fees from a company resident in the other Contracting State may be taxed by the company's State of residence on those fees and similar payments.
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