The Austrian Supreme Administrative Court clarified when a director’s activities are exercised in the other contracting state. On the basis of this judgment, Sarah Haubmann discusses the various possible allocation rules for a director’s remuneration in tax treaties. In connection with the income falling under the tax treaty with Russia 2003, there are good arguments that the consideration of the authentic English language version of the treaty and the French OECD MC version require the income to fall under Art 16 of the tax treaty with Russia 2003. Sarah Haubmann analyzes where a director’s activities are exercised for purposes of Art 15 para 1 OECD MC and gives an overview of the previous German case law. As Art 11 para 1 of the tax treaty with the USSR 1982 differs from Art 15 para 1 OECD MC, she also discusses the different calculation methods of the 183-day period.