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<h1>Directors' fees taxation: state where the company is resident may tax fees paid to non-resident board members.</h1> Directors' fees and comparable payments received as a board member may be taxed in the Contracting State where the company is resident under Article 17 of the DTAA; such fees derived by a resident of one State in his capacity as a director of a company resident in the other State may be taxed by that other State.