Directors' fees: payment to a resident may be taxed in the state where the company resides under tax treaty rules. Directors' fees paid to a resident of one Contracting State for services 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 such remuneration to the State of the company under the tax treaty.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees: payment to a resident may be taxed in the state where the company resides under tax treaty rules.
Directors' fees paid to a resident of one Contracting State for services 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 such remuneration to the State of the company under the tax treaty.
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