Taxation of directors' fees: payments to nonresident directors and top executives may be taxed where the company is resident. Directors' fees and similar payments received by a resident 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. Similarly, salaries, wages and similar remuneration paid to a resident for top level managerial office held in a company resident in the other Contracting State may be taxed in the State of the company's residence.