Directors' fees taxation: company residence permits source-state taxation of board remuneration under the tax treaty. Directors' fees 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 may be taxed in that other State; the provision links taxation to the capacity of the recipient and the residence of the paying company under the tax treaty.
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: company residence permits source-state taxation of board remuneration under the tax treaty.
Directors' fees 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 may be taxed in that other State; the provision links taxation to the capacity of the recipient and the residence of the paying company under the tax treaty.
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