Article 16 – Directors Fees

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

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.

Characteristics