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Directors' Fees
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.... in his capacity as a member of the board of directors or a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. This provision shall also ap....
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....ceived by a resident of a Contracting State consequent to some personal activity as a partner of a company, other than a company having a share capital which is a resident of the other Contracting Sta....