Director's fees taxable only in the state of the company under DTAA, limiting cross-border taxation. Director's fees and analogous payments received by a resident of one Contracting State for service as a member of the board of directors of a company resident in the other Contracting State are taxable exclusively in the State where the company is resident, allocating taxing rights over such board-related remuneration to the source/company State and excluding the resident State from taxing those payments under the 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.
Director's fees taxable only in the state of the company under DTAA, limiting cross-border taxation.
Director's fees and analogous payments received by a resident of one Contracting State for service as a member of the board of directors of a company resident in the other Contracting State are taxable exclusively in the State where the company is resident, allocating taxing rights over such board-related remuneration to the source/company State and excluding the resident State from taxing those payments under the treaty.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
