Directors' fees and managerial remuneration taxed in the State where the employing or resident company is located. Directors' fees and similar payments received by a resident of one Contracting State for board membership of a company resident in the other Contracting State may be taxed in that other State. Likewise, salaries, wages and similar remuneration paid to a resident for serving in a top-level managerial position of a company resident in the other State may be taxed in the State where the employing company is resident.
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 and managerial remuneration taxed in the State where the employing or resident company is located.
Directors' fees and similar payments received by a resident of one Contracting State for board membership of a company resident in the other Contracting State may be taxed in that other State. Likewise, salaries, wages and similar remuneration paid to a resident for serving in a top-level managerial position of a company resident in the other State may be taxed in the State where the employing company is resident.
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