ARTICLE 16
Directors' Fees
(1) Directors' fees and other similar remuneration gained by a resident of a Contracting State as a member of the board of directors of a company situated in the other Contracting State shall be taxable only in the other Contracting state.
(2) Salaries, wages and other similar remunerations gained by a resident of a Contracting state as an official of a senior management (leadership positions) in a company resident in the other Contracting state shall be taxable only in the other Contracting state.