- 1
- Directors' fees or other remuneration derived by a resident of one of the States 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 State may be taxed in that other State.
- 2
- Where the remuneration mentioned in paragraph 1 is derived by a person who exercises activities of a regular and substantial character in a permanent establishment situated in the State other than the State of which the company is a resident and the remuneration is deductible in determining the taxable profits of that permanent establishment, then, notwithstanding the provisions of paragraph 1, the remuneration, to the extent to which it is so deductible, may be taxed in the State in which the permanent establishment is situated.
