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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.

ARTICLE 16

Directors' Fees and Remuneration of Top-Level Managerial Officials

(1) Directors' fees and other similar remuneration derived by a resident of a Contracting State in his capacity as a member of the board of directors or any other similar body of a company that is a resident of the other Contracting State may be taxed in that other Contracting State.

(2) Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as a member of senior management in a company that is a resident of the other Contracting State may be taxed in that other Contracting State.