Directors' fees may be taxed in the state where the company is resident under the applicable double tax treaty. Article 17 provides that directors' fees and similar payments derived by a resident of one Contracting State for serving as a board member of a company resident in the other Contracting State may be taxed in that other State, thereby assigning taxing rights to the State of the company's residence for such board membership remuneration.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the state where the company is resident under the applicable double tax treaty.
Article 17 provides that directors' fees and similar payments derived by a resident of one Contracting State for serving as a board member of a company resident in the other Contracting State may be taxed in that other State, thereby assigning taxing rights to the State of the company's residence for such board membership remuneration.
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