Why this is treaty-specific, not general
Treaties differ on rates, on whether credit or exemption is used to relieve double taxation, and on how director's fees, salary and dividends are each treated, so no single rule describes every country's position accurately.
The UK side, no withholding on dividends and PAYE on director's fees, is only ever half the picture; your home country's tax return and its treatment of foreign income decide the real cost.






