Directors' fees may be taxed in the State where the company is resident, allocating taxing rights to the source State. Directors' fees paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating primary taxing rights to the source State under the Double Taxation Avoidance Agreement.
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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, allocating taxing rights to the source State.
Directors' fees paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating primary taxing rights to the source State under the Double Taxation Avoidance Agreement.
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