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Directors' fees: taxation may occur in the state where the company is resident under the DTAA. Directors' fees and analogous payments received by a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating taxing rights over such remuneration to the company's State of residence under the double taxation agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees: taxation may occur in the state where the company is resident under the DTAA.
Directors' fees and analogous payments received by a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in the State where the company is resident, allocating taxing rights over such remuneration to the company's State of residence under the double taxation agreement.
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