Taxation of artistes and sportspersons: source-state may tax performance income, except when substantially publicly funded, then resident taxation. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State. Income arising to another person for such activities may also be taxed in the State where the activities are exercised. If 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 of the entertainer or sportsperson.
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 sportspersons: source-state may tax performance income, except when substantially publicly funded, then resident taxation.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State. Income arising to another person for such activities may also be taxed in the State where the activities are exercised. If 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 of the entertainer or sportsperson.
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