Directors' fees taxable in the source state when services are rendered for a company resident in that state. Directors' fees paid to a resident of one Contracting State for services as a board member of a company resident in the other Contracting State may be taxed in the State where that company is resident, treating such payments for board membership as taxable in the source State under the tax treaty.
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 taxable in the source state when services are rendered for a company resident in that state.
Directors' fees paid to a resident of one Contracting State for services as a board member of a company resident in the other Contracting State may be taxed in the State where that company is resident, treating such payments for board membership as taxable in the source State under the tax treaty.
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