Director's fees taxation may arise in source state where the company is resident under treaty. Director's fees paid to a resident of one Contracting State for board membership of a company resident in the other Contracting State may be taxed in the state where the company is resident, allocating taxing entitlement over such director remuneration to the source state under the treaty framework.
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Provisions expressly mentioned in the judgment/order text.
Director's fees taxation may arise in source state where the company is resident under treaty.
Director's fees paid to a resident of one Contracting State for board membership of a company resident in the other Contracting State may be taxed in the state where the company is resident, allocating taxing entitlement over such director remuneration to the source state under the treaty framework.
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