Article 16. DIRECTORS' FEES
U.S. Income Tax Treaty — Ukraine Technical Explanation – 1994 · 2026-10-03 edition · updated 2026-10-04 · United States
This Article provides that a Contracting State may tax the
director's fees and similar payments paid by a company that is a resident of that State for services performed by a resident of the other Contracting State in his capacity as a director of the company. For this purpose, "similar payments" includes fixed salaries (or the portion thereof) paid for services performed as a director. Only the State of residence of the director, however, may tax any portion of the remuneration that is derived in respect of services performed in that State.
This article is subject to the provisions of the saving clause of paragraph 3 of Article 1 (General Scope).
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