Directors' fees: taxation may be imposed by the state where the paying company is resident, despite recipient's residence. Directors' fees and similar payments paid for service as a board member of a company resident in the other Contracting State may be taxed in the State where the paying company is resident, allocating the primary taxing right to that source State irrespective of the recipient's residence under the Double Taxation Agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees: taxation may be imposed by the state where the paying company is resident, despite recipient's residence.
Directors' fees and similar payments paid for service as a board member of a company resident in the other Contracting State may be taxed in the State where the paying company is resident, allocating the primary taxing right to that source State irrespective of the recipient's residence under the Double Taxation Agreement.
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