- 1
- Directors' fees and other remuneration derived by a resident of the Netherlands in his capacity as a member of the board of directors of a company which is a resident of the Philippines may be taxed in the Philippines.
- 2
- Directors' fees and other remuneration derived by a resident of the Philippines in his capacity as a "bestuurder" or a "commissaris" of a company which is a resident of the Netherlands may be taxed in the Netherlands.
- 3
- Where the remuneration mentioned above is derived by persons, who exercise activities in real and regular functions in a permanent establishment situated in the other State than the State of which the company is a resident, and is borne as such by that permanent establishment, then, notwithstanding the provisions of paragraphs 1 and 2, such remuneration may be taxed in the State in which the permanent establishment is situated.
