Directors' fees may be taxed in the state where the company is resident under the DTAA. Directors' fees and similar payments received by a resident of one Contracting State for serving on the board of a company resident in the other Contracting State may be taxed in the Contracting State where the company is resident, allocating primary taxing rights over such board membership remuneration to the company's state of residence under the applicable Double Taxation Avoidance Agreement.