Directors' fees: cross border payments to board members may be taxed in the company's State, employment rules may apply.

Directors' fees and analogous payments received by a resident for board membership of a company resident in the other Contracting State may be taxed in the State where the company is resident. Payments for day-to-day managerial or technical duties by a director, and remuneration for personal activity as a partner in certain non share capital companies, may instead be taxed under the treaty provisions applicable to employment income as set out in Article 15.

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