ARTICLE 16
Directors' Fees
(1) Directors' fees and other similar payments derived by a resident of a Contracting State in that resident'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 State.
(2) Salaries, wages and other remuneration derived by a resident of a Contracting State in that resident's capacity as an officer, or an official responsible under commercial law for the overall direction of the affairs, of a company which is a resident of the other Contracting State may be taxed in that other State.