ARTICLE 16 – INDIA USA TREATY
Directors’ fees and similar payments
derived by a resident of a Contracting State
in his capacity
as a member of the Board of Directors of a company which is a resident of the other Contracting State
may be taxed in that other State.
ARTICLE 16 – ISSUES FOR CONSIDERATION
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MEANING OF DIRECTOR’S FEES AND OTHER SIMILAR PAYMENTS
DIRECTOR IN DUAL CAPACITY
TAXATION OF TOP LEVEL MANAGERIAL REMUNERATION
Salaries, wages and other similar remuneration
derived by a resident of a Contracting State
in his capacity as an official in a top-level managerial position
of a company which is a resident of other Contracting State
may be taxed in that other State.
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Characteristics