Directors' fees taxability: board service payments to a resident may be taxed in the company's resident 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 are subject to taxation in the State where the company is resident, permitting the source State to tax such remuneration under the Double Taxation Avoidance Agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxability: board service payments to a resident may be taxed in the company's resident 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 are subject to taxation in the State where the company is resident, permitting the source State to tax such remuneration under the Double Taxation Avoidance Agreement.
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