Taxation of entertainers and sportspersons: performance income may be taxed where activities occur, subject to exchange programme exception. Income of residents who perform as entertainers or sportspersons may be taxed in the State where the activities are exercised, notwithstanding provisions on employment or business income; the same applies where payments accrue to a third party. An exception provides that such income is taxable only in the resident State when the activities occur under a cultural or sports exchange programme approved by both Contracting States.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of entertainers and sportspersons: performance income may be taxed where activities occur, subject to exchange programme exception.
Income of residents who perform as entertainers or sportspersons may be taxed in the State where the activities are exercised, notwithstanding provisions on employment or business income; the same applies where payments accrue to a third party. An exception provides that such income is taxable only in the resident State when the activities occur under a cultural or sports exchange programme approved by both Contracting States.
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