Directors' fees taxable exclusively in the state where the company is resident under the treaty's allocation rule. Directors' fees paid to a resident of one Contracting State for service on the board of a company resident in the other Contracting State are taxable only in the State where the company is resident, allocating such board remuneration to the company's State of residence.
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.
Directors' fees taxable exclusively in the state where the company is resident under the treaty's allocation rule.
Directors' fees paid to a resident of one Contracting State for service on the board of a company resident in the other Contracting State are taxable only in the State where the company is resident, allocating such board remuneration to the company's State of residence.
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