Directors' fees may be taxed in the State where the company is resident when earned by a non-resident director. Directors' fees and analogous payments received by a resident of one Contracting State for service as a board member of a company resident in the other Contracting State are taxable in the State where the company is resident, allocating primary taxing rights over board remuneration to the company's State of residence under the double taxation agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees may be taxed in the State where the company is resident when earned by a non-resident director.
Directors' fees and analogous payments received by a resident of one Contracting State for service as a board member of a company resident in the other Contracting State are taxable in the State where the company is resident, allocating primary taxing rights over board remuneration to the company's State of residence under the double taxation agreement.
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