Directors' fees taxation: fees paid for board supervisory roles may be taxed in the State where the company is resident. Article 16 provides that directors' fees and similar payments received by a resident of one Contracting State for serving as a board member with supervisory functions in a company resident in the other Contracting State may be taxed in that other State, allocating taxing rights to the State where the company is resident.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxation: fees paid for board supervisory roles may be taxed in the State where the company is resident.
Article 16 provides that directors' fees and similar payments received by a resident of one Contracting State for serving as a board member with supervisory functions in a company resident in the other Contracting State may be taxed in that other State, allocating taxing rights to the State where the company is resident.
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