Income of artistes and athletes may be taxed by the source State unless exempt under a cultural exchange programme.

Income of resident entertainers and athletes from personal activities exercised in the other Contracting State may be taxed by that other State, but is exempt from such tax if the activities are performed pursuant to a special programme for cultural exchange agreed between the Governments; similarly, income accruing to a person other than the performer may be taxed by the source State, subject to the same cultural exchange exemption.

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