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Taxation of directors' fees: company-resident State may tax remuneration paid to nonresident board members under the treaty. Directors' fees and similar payments derived 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, allowing that State to impose tax at source on remuneration for board membership under the DTAA framework.
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Provisions expressly mentioned in the judgment/order text.
Taxation of directors' fees: company-resident State may tax remuneration paid to nonresident board members under the treaty.
Directors' fees and similar payments derived 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, allowing that State to impose tax at source on remuneration for board membership under the DTAA framework.
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