Directors' fees may be taxed in the company's state when payable to a non-resident board member. Directors' fees and analogous payments made to 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, thereby allocating source state taxing authority over such remuneration.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the company's state when payable to a non-resident board member.
Directors' fees and analogous payments made to 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, thereby allocating source state taxing authority over such remuneration.
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