Directors' fees may be taxed in the state where the payor company is resident under the tax treaty. Directors' fees and analogous payments paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in that other State, allocating primary taxing rights over such board membership remuneration to the State where the payor company is resident under the double taxation agreement.
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 may be taxed in the state where the payor company is resident under the tax treaty.
Directors' fees and analogous payments paid to a resident of one Contracting State for service as a board member of a company resident in the other Contracting State may be taxed in that other State, allocating primary taxing rights over such board membership remuneration to the State where the payor company is resident under the double taxation agreement.
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