An individual exercising a director’s mandate
within a company will be taxable on the director’s fees
in the state where the company is situated. This means that
director’s fees are taxable in the state where the company
paying the director’s fees is located, regardless of whether
the directorship has been physically performed there or not.
Exceptions
The
183-days rule and the frontier workers’ regulation do
not apply to directors.
It should be noted that “director’s fees”
is a restricted concept and that certain treaties contain
specific rules relating to the type of qualifying corporations.
Whether or not the article on directors’ fees applies
should be checked on a case by case basis.
