Directors' fees may be taxed in the state where the company is resident under DTAA provisions. Article 17 provides that directors' fees and similar payments paid to a resident of one Contracting State for services as a director or comparable governing body member of a company resident in the other Contracting State may be taxed in the State where that company is resident.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the state where the company is resident under DTAA provisions.
Article 17 provides that directors' fees and similar payments paid to a resident of one Contracting State for services as a director or comparable governing body member of a company resident in the other Contracting State may be taxed in the State where that company is resident.
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