- 1
- Directors’ fees or other remuneration derived by a resident of a Contracting State in his capacity as a member of the board of directors, a ‘‘bestuurder’’ or a ‘‘commissaris’’ of a company which is a resident of the other Contracting State may be taxed in that other State.
- 2
- A ‘‘bestuurder’’ or ‘‘commissaris’’ of a Netherlands company means a person who is nominated as such by the general meeting of shareholders or by any other competent body of such company and is charged with the general management of the company and the supervision thereof, respectively.
- 3
- Where the remuneration mentioned in paragraph 1 is derived by persons, who exercise activities in real and regular functions in a permanent establishment situated in the first-mentioned Contracting State mentioned in paragraph 1, and the remuneration is borne as such by that permanent establishment, then, notwithstanding the provisions of paragraph 1 of this Article, such remuneration may be taxed in the State in which the permanent establishment is situated.
