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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Philippines: double taxation agreement, Article 15: Director's fees


Directors’ fees and remuneration in respect of the discharge of day-to-day functions of a managerial or technical nature, derived from a company which is a resident of a Contracting State by a resident of the other Contracting State who is a member of the board of directors of that company, may be taxed in the first-mentioned State.