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 ... Summary
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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