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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, attendance allowance and other similar payments received by a resident of a Contracting State in his or her capacity as a member of the board of directors of a company that is a resident of the other Contracting State may be taxed in that other State.

(2) However, the payments derived by such person in some other capacity shall be taxable, depending on the context, according to the conditions referred to in either Article 14 or paragraph (1) of Article 15 of this Convention.