Taxation of entertainers and sports persons: income from performances may be taxed in the state where activities are exercised. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where those activities are performed, including where income accrues to another person. That source-based taxing right is subject to an exception: activities substantially supported by public funds of a Contracting State or its subdivisions are taxable only in the performer's 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 and sports persons: income from performances may be taxed in the state where activities are exercised.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where those activities are performed, including where income accrues to another person. That source-based taxing right is subject to an exception: activities substantially supported by public funds of a Contracting State or its subdivisions are taxable only in the performer's State of residence.
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