Taxation of entertainers and athletes: source state may tax performance income, subject to public funds and third party payment exceptions.

Income of resident entertainers and athletes from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed. If such income accrues to another person, it may likewise be taxed in the State where the activities occur. Exceptions: income is taxable only in the residence State if the activities are supported wholly or substantially from the residence State's public funds; conversely, if the other person receiving the income is supported wholly or substantially from the public funds of the State where the activities are exercised, that income is taxable only in that State.

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