background image
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 derived by a resident of a Contracting State in his or her capacity as a member of the board of directors or any other similar office of the company which is a resident of the other Contracting State may be taxed in that other State.

(2) However, the remuneration received by the concerned persons in some other capacity shall be taxable, depending on the case, under conditions provided either under Article 14, or paragraph (1) of Article 15, of this Convention.