Taxation of entertainers and sportspersons may occur where services are performed; public funding can limit taxation to residence state. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, and such income may be taxed there even if it accrues to another person; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is taxable only in the State of residence.