Taxation of entertainers and sportspersons: source-state may tax performance income, subject to public funding exception. Income earned by a resident entertainer or sportsperson from personal activities performed in the other Contracting State may be taxed in that other State, and where such income accrues to a third party it may nonetheless be taxed in the State where the activities occur; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is taxable only in the entertainer's or sportsperson'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 entertainers and sportspersons: source-state may tax performance income, subject to public funding exception.
Income earned by a resident entertainer or sportsperson from personal activities performed in the other Contracting State may be taxed in that other State, and where such income accrues to a third party it may nonetheless be taxed in the State where the activities occur; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is taxable only in the entertainer's or sportsperson's State of residence.
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