Taxation of entertainers and sportspersons: source State may tax performance income, with a public-funding exception.

Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, whether the income accrues to the performer or to another person. Where activities are substantially supported by public funds of either Contracting State or their political subdivisions or local authorities, the income is taxable only in the State of residence.

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