Directors' fees taxable in source State for board service in resident company under DTAA, affecting cross-border taxation. Directors' fees payable 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 by the State where the company is resident, allocating taxing rights to the source State for remuneration arising from board membership under the double taxation agreement.
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Provisions expressly mentioned in the judgment/order text.
Directors' fees taxable in source State for board service in resident company under DTAA, affecting cross-border taxation.
Directors' fees payable 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 by the State where the company is resident, allocating taxing rights to the source State for remuneration arising from board membership under the double taxation agreement.
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