Directors' fees taxation: source State may tax fees paid to nonresident board members under the tax treaty. Directors' fees and analogous remuneration paid to a resident of one Contracting State for services as a board member of a company resident in the other Contracting State may be taxed by the State where the company is resident, allocating taxing power to the source State for such board-related payments under the bilateral tax treaty.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxation: source State may tax fees paid to nonresident board members under the tax treaty.
Directors' fees and analogous remuneration paid to a resident of one Contracting State for services as a board member of a company resident in the other Contracting State may be taxed by the State where the company is resident, allocating taxing power to the source State for such board-related payments under the bilateral tax treaty.
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