Taxation of entertainers: income from performances may be taxed where services are performed, unless substantially publicly funded. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, including income accruing to third parties from such activities; however, where the activities are substantially supported by public funds of one or both Contracting States or their political subdivisions or local authorities, the income is taxable only in the State of residence.
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: income from performances may be taxed where services are performed, unless substantially publicly funded.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, including income accruing to third parties from such activities; however, where the activities are substantially supported by public funds of one or both Contracting States or their political subdivisions or local authorities, the income is taxable only in the State of residence.
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