Directors' fees may be taxed in the state where the company is resident for board service provided there. Fees and analogous payments received 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 that other State; the provision allocates primary taxing rights over board membership remuneration to the State where the company is resident.
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 may be taxed in the state where the company is resident for board service provided there.
Fees and analogous payments received 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 that other State; the provision allocates primary taxing rights over board membership remuneration to the State where the company is resident.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.