Taxation of entertainers and athletes: income generally taxable where performances occur, with public funded exchange exceptions.

Income of entertainers and athletes is taxable in the State where their personal activities are performed, including when payments accrue to a third person, notwithstanding Articles 7, 15 and 16. Exception: if activities form part of a cultural or sports exchange programme agreed by both States and are supported wholly or substantially from the public funds of the resident's State, the income is taxable only in the State of residence; a corresponding rule applies where public funds of the other State support activities and income accrues to a third person.

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