Directors fees for board service may be taxed in the State where the company is resident under the treaty. Directors fees paid to a resident of one Contracting State for service as a member of a company's board, supervisory board or similar organ may be taxed in the Contracting State where the company is resident, allocating primary taxing power over remuneration for board service to the State of the company rather than to the director's State.
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 for board service may be taxed in the State where the company is resident under the treaty.
Directors fees paid to a resident of one Contracting State for service as a member of a company's board, supervisory board or similar organ may be taxed in the Contracting State where the company is resident, allocating primary taxing power over remuneration for board service to the State of the company rather than to the director's State.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.