Directors' fees may be taxed in the state where the company is resident when paid to a nonresident director.

Article 15 provides that directors' fees and similar payments received by 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 source-based taxing power over cross-border director remuneration under the treaty.

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