ARTICLE 17
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 supervisors or of a similar board of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.
(2) 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 resident of the other Contracting State may be taxed in that other Contracting State.