Directors' fees: remuneration for board service may be taxed in the state where the paying company is resident. Directors' fees and analogous payments to a resident for service as a board member may be taxed in the Contracting State where the company paying those fees is resident, allocating source-based taxing power over such remuneration to the State of the company's residence under the treaty.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees: remuneration for board service may be taxed in the state where the paying company is resident.
Directors' fees and analogous payments to a resident for service as a board member may be taxed in the Contracting State where the company paying those fees is resident, allocating source-based taxing power over such remuneration to the State of the company's residence under the treaty.
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