Directors' fees taxation may be imposed in the company's State; executive salaries in top managerial roles are similarly taxable. Article 17 permits taxation in the State where the employing company resides of directors' fees and similar payments received by a resident for board membership, and likewise permits taxation in that State of salaries, wages and comparable remuneration paid to a resident serving in a top-level managerial position of the resident company.
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 taxation may be imposed in the company's State; executive salaries in top managerial roles are similarly taxable.
Article 17 permits taxation in the State where the employing company resides of directors' fees and similar payments received by a resident for board membership, and likewise permits taxation in that State of salaries, wages and comparable remuneration paid to a resident serving in a top-level managerial position of the resident company.
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