Director's fees may be taxed in the state where the paying company is resident, allocating source taxation accordingly. Director's fees paid to a person as a member of the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, permitting that State to impose tax on such fees derived by a director who is a resident of the other Contracting State.
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 paying company is resident, allocating source taxation accordingly.
Director's fees paid to a person as a member of the board of a company resident in the other Contracting State may be taxed in the State where the company is resident, permitting that State to impose tax on such fees derived by a director who is a resident of the other Contracting State.
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