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.
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: 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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