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of <h1>Directors' Fees Taxation: Cross-Border Income Allocation Clarified Under UN Model International Tax Guidelines</h1> The statutory provision addresses taxation of directors' fees and top-level managerial remuneration in international tax contexts. Under the UN Model, directors' fees and salaries earned by residents from a company in another contracting state can be taxed in the state where the company is resident. This provision aims to clarify taxation rights for professional services rendered across different jurisdictions, ensuring appropriate allocation of tax revenues between contracting states.
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