Directors' fees: taxable in the state where the company is resident when derived by a nonresident board member. Directors' fees and comparable payments received by a resident of one Contracting State as a board member of a company resident in the other Contracting State may be taxed in that other Contracting State, treating remuneration for board service as falling within the taxing rights of the company's state of residence under the applicable double taxation agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees: taxable in the state where the company is resident when derived by a nonresident board member.
Directors' fees and comparable payments received by a resident of one Contracting State as a board member of a company resident in the other Contracting State may be taxed in that other Contracting State, treating remuneration for board service as falling within the taxing rights of the company's state of residence under the applicable double taxation agreement.
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