Directors' fees taxation: source state may tax payments to non-resident directors for board service under the tax treaty. Directors' fees and similar 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; the provision allocates source-state taxing rights over remuneration for directorial services under the tax treaty.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxation: source state may tax payments to non-resident directors for board service under the tax treaty.
Directors' fees and similar 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; the provision allocates source-state taxing rights over remuneration for directorial services under the tax treaty.
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