Directors' fees may be taxed in the state where the company is resident under the DTAA allocation rule. Directors' fees and similar payments received by 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, under Article 16 of the applicable Double Taxation Avoidance Agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the state where the company is resident under the DTAA allocation rule.
Directors' fees and similar payments received by 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, under Article 16 of the applicable Double Taxation Avoidance Agreement.
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