Directors' fees taxation: treaty permits taxation in the state where the company is resident under the treaty. Directors' fees and similar payments received by a resident of one Contracting State for serving on the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, permitting source-country taxation of remuneration for board membership under the bilateral tax treaty.
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: treaty permits taxation in the state where the company is resident under the treaty.
Directors' fees and similar payments received by a resident of one Contracting State for serving on the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, permitting source-country taxation of remuneration for board membership under the bilateral tax treaty.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.