Directors' fees may be taxed in the state where the employing company is resident when earned by a nonresident director. Article 16 provides that directors' fees and other similar payments derived by a resident of one Contracting State in his capacity as a member of the board of directors of a company resident in the other Contracting State may be taxed in that other State; the provision allocates taxing rights over board-membership remuneration to the State of the company's residence.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the state where the employing company is resident when earned by a nonresident director.
Article 16 provides that directors' fees and other similar payments derived by a resident of one Contracting State in his capacity as a member of the board of directors of a company resident in the other Contracting State may be taxed in that other State; the provision allocates taxing rights over board-membership remuneration to the State of the company's residence.
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