DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State. 2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 12 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 12 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Elimination of Double Taxation, Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which derived by a person person, to whom paragraph 1 applies derives applies, from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 8 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 6 contracts
Samples: Double Taxation Avoidance Agreement, Double Tax Agreement, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1413.
Appears in 6 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' Director’s fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 5 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Directors fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 4 contracts
Samples: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may as an employee, shall be taxed in accordance with the provisions of Article 14.
Appears in 4 contracts
Samples: Income Tax Treaty, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives derived from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments remuneration derived by a resident of a Contracting State 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 Contracting State.
2. The However, remuneration which a person to whom paragraph 1 applies derives from received by the company persons concerned in respect of the discharge of day-to-day functions of a managerial or technical nature any other capacity may be taxed taxed, as the case may be, in accordance with the provisions of Article 1414 or Article 15.
Appears in 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' Director’s fees and other similar payments derived by a resident of a Contracting State in his the capacity as of a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
Appears in 3 contracts
Samples: Double Tax Agreement, Double Taxation Agreement, Double Tax Agreement
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 of this Article applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 3 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415 (Dependent Personal Services).
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Director's fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 I applies derives derived from the company in respect of the discharge of day-day- to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 2 contracts
Samples: Agreement Between the Government of the Republic of Indonesia and the Government of the People's Republic of Bangladesh for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the People's Republic of Bangladesh for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organization of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or a similar organ of a company with share capital which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14XV.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State 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 Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a one of the Contracting State States in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The However, the provisions of Article 14 shall apply to any remuneration which a person to whom paragraph 1 applies derives from derived by such member of the board of directors of such company in respect of services rendered to the discharge of day-to-day functions of a managerial or technical nature may be taxed company in accordance with the provisions of Article 14any capacity other than as such director.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415 (Dependent Personal Services).
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. (1. Directors' ) Director's fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors on a similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
(2. ) The remuneration which a person to whom paragraph 1 (1) applies derives from the company in respect of at the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions previsions of Article 1415.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1414 (Personal Services).
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1414 (Personal services).
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or similar body of a joint-stock company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of this Article 14shall also apply to payments derived by persons for the exercising of functions similar to those mentioned in the preceding paragraph.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' ’ fees and similar other payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other Contracting State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State territory in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State territory may be taxed in that other Contracting Stateterritory.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1412.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration Salaries, wages and other similar remuniration derived by a resident of a Contractng State in his capacity as an official in a top – level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of the country of a Contracting State Party in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the country of the other Contracting State Party may be taxed in that other Contracting Statecountry.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415 (Dependent Personal Services).
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting Contract- ing State in his or her capacity as a member of the board Board of directors Directors or similar body of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 one applies derives derived from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14article 15.
Appears in 1 contract
Samples: Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom provisions of paragraph 1 applies derives shall likewise apply to officials of a company in top level managerial positions as to payments received in that capacity from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14company.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' Directors fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or an equivalent body of a company which that is a resident of the other Contracting State may be taxed in the State where such fees or payments arise.
2. Directors fees and other similar payments shall be deemed to arise in the Contracting State in which the company is resident except to the extent that such fees or payments are paid in respect of attendance at meetings held in the other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or other similar organ of a company which is a resident of the other Contracting State may shall be taxed taxable only in that other the first-mentioned Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Director's fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a his company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives derived from the company in respect of the discharge of day-day to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his that person’s capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in that person’s capacity as an official in a top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
Appears in 1 contract
Samples: Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415 (Dependent personal services).
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Directors fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-day- to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' Director’s fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other Contracting State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Director's fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives derived from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State State, may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415 (Dependent Personal Services).
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors or any other similar body of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Director's fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration remuneration, which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415. (Dependent Personal Services).
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The If the remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature nature, it may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments other remuneration derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from For the company in respect purpose of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14paragraph 1, the term “member of the board of directors” includes any person who is charged with the general management of the company and any person who is charged with the supervision thereof.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or supervisory board or of another similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' Directors fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Confracting State in his capacity as an official in a top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
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Samples: Double Taxation Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or another similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
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Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415 (Dependent Personal Services).
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DIRECTORS' FEES. 1. Directors' Director's fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
23. The remuneration which a person to whom paragraph 1 applies derives derived from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415. 4.
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DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his that person’s capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in the individual’s capacity as an official in a top- level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
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Samples: Ataf Model Tax Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a one of the Contracting State States in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The In relation to remuneration which of a person to whom paragraph 1 applies derives director of a company derived from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with nature, the provisions of Article 1415 shall apply as if the remuneration were remuneration of an employee in respect of an employment and as if references to “employer” were references to the company.
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Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his that person’s 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 Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official occupying a top-level managerial position in a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature other Contracting State may be taxed in accordance with the provisions of Article 14that other State.
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DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar other organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
DIRECTORS' FEES. 1. Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1415.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DIRECTORS' FEES. 1. Directors' ’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board Board of directors Directors or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 1414 (Dependent Personal Services).
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DIRECTORS' FEES. 1. Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may shall be taxed taxable only in that other Contracting State.
2. The Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a person to whom paragraph 1 applies derives from the company in respect resident of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.other Contracting State shall be
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DIRECTORS' FEES. 1. Directors' ” fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
2. The remuneration which a person to whom paragraph 1 of this Article applies derives from the company in respect of the discharge of day-toof-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 14.
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