Directors' fees may be taxed in the contracting state where the company is resident, under the tax treaty. Directors' fees and similar 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 that other Contracting State, treating the company's residence as the relevant taxing jurisdiction for such remuneration under the Double Tax Avoidance Agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the contracting state where the company is resident, under the tax treaty.
Directors' fees and similar 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 that other Contracting State, treating the company's residence as the relevant taxing jurisdiction for such remuneration under the Double Tax Avoidance Agreement.
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