Directors' fees taxation: fees paid to resident directors can be taxed in the state where the company is resident. Directors' fees and analogous payments made to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, treating such remuneration as sourced to the company's State under the double taxation agreement framework.
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 taxation: fees paid to resident directors can be taxed in the state where the company is resident.
Directors' fees and analogous payments made to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, treating such remuneration as sourced to the company's State under the double taxation agreement framework.
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