Directors' fees taxation: source state may tax remuneration for board membership under the tax treaty allocation rule. Directors' fees and similar payments received by a resident of one Contracting State for acting as a member of the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating source-State taxing rights over remuneration for directorships under the double taxation agreement.
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Directors' fees taxation: source state may tax remuneration for board membership under the tax treaty allocation rule.
Directors' fees and similar payments received by a resident of one Contracting State for acting as a member of the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating source-State taxing rights over remuneration for directorships under the double taxation agreement.
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