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 a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. In the case of a company which is a resident of Belgium, this provision shall also apply to payments derived in respect of the discharge of functions which, under the laws of Belgium, are regarded as functions of a similar nature as those exercised by a person referred to in the said provision. 2. Remuneration derived by a person referred to in paragraph 1 from a company which is a resident of a Contracting State in respect of the discharge of day-to-day functions of a managerial or technical, commercial or financial nature, shall be taxable in accordance with the provisions of Article 15, as if such remuneration were remuneration derived by an employee in respect of an employment and as if references to the "employer" were references to the company. This provision shall also apply to remuneration received by a resident of a Contracting State in respect of his day-to-day activity as a partner of a company, other than a company with share capital, which is a resident of Belgium.
Appears in 7 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 or a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. In the case of a company which is a resident of Belgium, this provision shall also apply to payments derived in respect of the discharge of functions which, under the laws of Belgium, are regarded as functions of a similar nature as those exercised by a person referred to in the said provision.
2. Remuneration derived by a person referred to in paragraph 1 from a company which is a resident of a Contracting State in respect of the discharge of day-to-day functions of a managerial or technical, commercial or financial nature, shall be taxable in accordance with the provisions of Article 15, as if such remuneration were remuneration derived by an employee in respect of an employment and as if references to the "employer" were references to the company. This provision shall also apply to remuneration received by a resident of a Contracting State in respect of his day-day- to-day activity as a partner of a company, other than a company with share capital, which is a resident of Belgium.
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 a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. In the case of a company which is a resident of Belgium, this provision shall also apply to payments derived in respect of the discharge of functions which, under the laws of Belgium, are regarded as functions of a similar nature as those exercised by a person referred to in the said provision.
2. Remuneration derived by a person referred to in paragraph 1 from a company which is a resident of a Contracting State in respect of the discharge of day-to-day functions of a managerial or technical, commercial or financial nature, shall be taxable in accordance with the provisions of Article 15, as if such remuneration were remuneration derived by an employee in respect of an employment and as if references to the "employer" « employer » were references to the company. This provision shall also apply to remuneration received by a resident of a Contracting State in respect of his day-to-day activity as a partner of a company, other than a company with share capital, which is a resident of Belgium.
Appears in 1 contract
Samples: Double Taxation Agreement