Directors' fees: taxable in the State where the company is resident, allocating source taxing rights over such remuneration. Directors' fees and analogous payments paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State are taxable in the State where that company is resident, conferring primary taxing rights over such remuneration to the source State rather than the director's State of residence.
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: taxable in the State where the company is resident, allocating source taxing rights over such remuneration.
Directors' fees and analogous payments paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State are taxable in the State where that company is resident, conferring primary taxing rights over such remuneration to the source State rather than the director's State of residence.
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