Directors' fees may be taxed in the company's resident State under the DTAA, affecting cross-border board pay. Payments characterized as directors' fees or similar remuneration 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 that other State under Article 16 of the DTAA.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the company's resident State under the DTAA, affecting cross-border board pay.
Payments characterized as directors' fees or similar remuneration 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 that other State under Article 16 of the DTAA.
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