Taxation of entertainers' and athletes' income: activities in one state may be taxed where performed, subject to public funding exceptions.

Income of an entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in the State where those activities are performed, including where payments accrue to another person; however, such income is taxable only in the resident State if the activities abroad are supported wholly or substantially from the resident State's public funds, and if the income accrues to a resident of the other State who is wholly or substantially supported from that other State's public funds, taxation is confined to that other State.

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