Directors' fees taxable in the company's state; top-level managerial remuneration likewise taxable under treaty. Article 16 permits taxation by the State where the company is resident of: directors' fees and similar payments received by a resident of the other Contracting State in his capacity as a board member; and salaries, wages and similar remuneration received by a resident of the other Contracting State in his capacity as a top-level managerial official.
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 in the company's state; top-level managerial remuneration likewise taxable under treaty.
Article 16 permits taxation by the State where the company is resident of: directors' fees and similar payments received by a resident of the other Contracting State in his capacity as a board member; and salaries, wages and similar remuneration received by a resident of the other Contracting State in his capacity as a top-level managerial official.
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