Directors' fees taxation: may be taxed in the state of the company's residence even if recipient is resident elsewhere. Article 16 of the OECD Model (2017) provides that fees and similar payments received by a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in that other State, allocating taxing power to the source State where the company is resident under the applicable DTAA.
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: may be taxed in the state of the company's residence even if recipient is resident elsewhere.
Article 16 of the OECD Model (2017) provides that fees and similar payments received by a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in that other State, allocating taxing power to the source State where the company is resident under the applicable DTAA.
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