Taxation of artistes and sportspersons: income from performances may be taxed where activities occur; public funded performances taxed only at residence. 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 a third party in respect of such activities may likewise be taxed in the State where the activities are performed. These rules do not apply to activities substantially supported by public funds of a Contracting State or its subdivisions; such 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: income from performances may be taxed where activities occur; public funded performances taxed only at residence.
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 a third party in respect of such activities may likewise be taxed in the State where the activities are performed. These rules do not apply to activities substantially supported by public funds of a Contracting State or its subdivisions; such income is taxable only in the State of residence of the entertainer or sportsperson.
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