Directors' fees: taxation may occur in the state where the company is resident, regardless of the director's residence. Payments characterised as directors' fees and similar remuneration received by 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 the state where the company is resident, allocating taxing jurisdiction over board-level remuneration to the company's residence under the tax treaty.
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: taxation may occur in the state where the company is resident, regardless of the director's residence.
Payments characterised as directors' fees and similar remuneration received by 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 the state where the company is resident, allocating taxing jurisdiction over board-level remuneration to the company's residence under the tax treaty.
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