Directors' fees may be taxed in the state where the company is resident under tax treaty source taxation rules. 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, identifying the company residence as the relevant nexus for source taxation of such remuneration under the double tax convention.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the state where the company is resident under tax treaty source taxation rules.
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, identifying the company residence as the relevant nexus for source taxation of such remuneration under the double tax convention.
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