Directors' fees may be taxed by the state where the company is resident, under source-based treaty rules. Article 16 provides that directors' fees and similar payments received by a resident of one Contracting State for service as a member of the board of a company resident in the other Contracting State may be taxed in that other State, assigning source-based taxing entitlement to the State where the company is resident.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed by the state where the company is resident, under source-based treaty rules.
Article 16 provides that directors' fees and similar payments received by a resident of one Contracting State for service as a member of the board of a company resident in the other Contracting State may be taxed in that other State, assigning source-based taxing entitlement to the State where the company is resident.
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