Taxation of visiting artistes and sportspersons permits source State taxation of performance income, with a public funding exception. Income of a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State, including where income accrues to a third party; however, if the activities are substantially supported by public funds of either Contracting State or their subdivisions, the income is taxable only in the State of residence.