Taxation of entertainers and sportspersons may be imposed by the State where services are performed, subject to public-funding exception. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, including income related to reputation; income accruing to a third person for such activities may likewise be taxed in the State where the activities occur. Activities wholly supported by public funds of one or both Contracting States or their subdivisions are excepted and taxable only in the 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 may be imposed by the State where services are performed, subject to public-funding exception.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, including income related to reputation; income accruing to a third person for such activities may likewise be taxed in the State where the activities occur. Activities wholly supported by public funds of one or both Contracting States or their subdivisions are excepted and taxable only in the State of residence.
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