Directors' fees may be taxed in the state where the company is resident; managerial pay is treated as employment income. Directors' fees and similar payments to a resident for service on a company's board may be taxed by the State where the company is resident; payments for analogous functions are included. Remuneration for day-to-day managerial or technical duties and payments for personal partner activities in a non share capital company are treated as employment income and taxed under the treaty employment provision.
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 may be taxed in the state where the company is resident; managerial pay is treated as employment income.
Directors' fees and similar payments to a resident for service on a company's board may be taxed by the State where the company is resident; payments for analogous functions are included. Remuneration for day-to-day managerial or technical duties and payments for personal partner activities in a non share capital company are treated as employment income and taxed under the treaty employment provision.
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