Directors' fees and top-level managerial remuneration may be taxed in the state where the employing company is resident. Article 18 permits taxation in the State of the company's residence of directors' fees and similar payments received by a resident as a board member, and of salaries, wages and similar remuneration received by a resident as an official in a top-level managerial position of a company resident in the other Contracting State.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees and top-level managerial remuneration may be taxed in the state where the employing company is resident.
Article 18 permits taxation in the State of the company's residence of directors' fees and similar payments received by a resident as a board member, and of salaries, wages and similar remuneration received by a resident as an official in a top-level managerial position of a company resident in the other Contracting State.
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