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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


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 of a similar body of a joint stock company which is a resident of the other Contracting State may be taxed in that other State.

The provisions of this Article shall apply also to payments received in respect of the performance of functions similar to those performed by a person referred to in the preceding paragraph.

(2) However, the remuneration that a person referred to in paragraph (1) receives from the company in respect of the performance of a daily managerial or technical function may be taxed in accordance with the provisions of Article 15.