Directors' fees and senior executive remuneration can be taxed by the state where the employing company is resident. Directors' fees and analogous payments received by a resident for service as a board member of a company resident in the other Contracting State may be taxed in that other State, and salaries, wages and similar remuneration paid to a resident for service as a top level managerial official of a company resident in the other Contracting State may likewise be taxed in that other State.
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 senior executive remuneration can be taxed by the state where the employing company is resident.
Directors' fees and analogous payments received by a resident for service as a board member of a company resident in the other Contracting State may be taxed in that other State, and salaries, wages and similar remuneration paid to a resident for service as a top level managerial official of a company resident in the other Contracting State may likewise be taxed in that other State.
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