Taxation of entertainers and sportspersons: source state may tax performance income, with a public funding exception. Income earned by artistes and sportspersons from personal performances in the other Contracting State is taxable in the State where the activities are exercised, including when such income accrues to a person other than the performer; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is taxable only in the resident State.
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: source state may tax performance income, with a public funding exception.
Income earned by artistes and sportspersons from personal performances in the other Contracting State is taxable in the State where the activities are exercised, including when such income accrues to a person other than the performer; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is taxable only in the resident State.
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