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.

ARTICLE 18

Directors' Fees

Directors' fees, attendance allowances 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, subject to the application of Articles 16 and 17 above, with respect to remuneration derived by the concerned persons in any other effective capacity.

If the company has one or more permanent establishments in the territory of the other Contracting State, directors' fees, attendance allowances and other similar payments described above shall be taxed under conditions laid down in Articles 10 and 12.