Taxation of artistes and sports persons: source-state taxing rights for performance income with public-funding exception to residence taxation. Income earned by a resident for personal activities as an entertainer or sportsperson in the other Contracting State may be taxed in the State where those activities are performed; income accruing to a third person may also be taxed in that State. If the visit is substantially supported by public funds of one or both Contracting States or their subdivisions, the income is 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 artistes and sports persons: source-state taxing rights for performance income with public-funding exception to residence taxation.
Income earned by a resident for personal activities as an entertainer or sportsperson in the other Contracting State may be taxed in the State where those activities are performed; income accruing to a third person may also be taxed in that State. If the visit is substantially supported by public funds of one or both Contracting States or their subdivisions, the income is taxable only in the performer's State of residence.
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