Directors' fees may be taxed in the state where the company is resident despite recipient residency. 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 may be taxed in the State where the company is resident, allocating primary taxing rights over such remuneration to the company's State of residence under the applicable double taxation agreement.
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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 despite recipient residency.
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 may be taxed in the State where the company is resident, allocating primary taxing rights over such remuneration to the company's State of residence under the applicable double taxation agreement.
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