Directors' fees and top manager remuneration may be taxed where the company is resident under the DTAA. Directors' fees and similar payments received by a resident for service on the board of a company resident in the other Contracting State may be taxed in that State, and salaries, wages and similar remuneration for service as a top-level managerial official of a company resident in the other State may also be taxed in the State where the company is resident.
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 and top manager remuneration may be taxed where the company is resident under the DTAA.
Directors' fees and similar payments received by a resident for service on the board of a company resident in the other Contracting State may be taxed in that State, and salaries, wages and similar remuneration for service as a top-level managerial official of a company resident in the other State may also be taxed in the State where the company is resident.
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