Directors' fees taxation: state where the company is resident may tax fees received by a non-resident director. Directors' fees paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed by the State where the company is resident; the provision treats such remuneration as source based income subject to taxation in the paying company's jurisdiction under the Double Tax Avoidance Agreement.
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: state where the company is resident may tax fees received by a non-resident director.
Directors' fees paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed by the State where the company is resident; the provision treats such remuneration as source based income subject to taxation in the paying company's jurisdiction under the Double Tax Avoidance Agreement.
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