Director's fees may be taxed in the state where the company is resident under the applicable tax treaty provisions. Director's fees and analogous remuneration paid to a resident of one Contracting State for services as a board member of a company resident in the other Contracting State are taxable by the State where the company is resident, allocating primary taxing rights over such board-related payments to the company-resident jurisdiction under the treaty.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Director's fees may be taxed in the state where the company is resident under the applicable tax treaty provisions.
Director's fees and analogous remuneration paid to a resident of one Contracting State for services as a board member of a company resident in the other Contracting State are taxable by the State where the company is resident, allocating primary taxing rights over such board-related payments to the company-resident jurisdiction under the treaty.
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