Taxation of entertainers and athletes: performance income taxable where activities occur, subject to public funding exemption. Income earned by entertainers and athletes from personal performances may be taxed in the Contracting State where performed, even if other treaty provisions on personal services or business profits would otherwise apply. If the income accrues to a person other than the performer, it remains taxable in the State of performance. These rules do not apply when the performer's visit is wholly or substantially funded from the public funds of the other Contracting State or its subdivisions.
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 athletes: performance income taxable where activities occur, subject to public funding exemption.
Income earned by entertainers and athletes from personal performances may be taxed in the Contracting State where performed, even if other treaty provisions on personal services or business profits would otherwise apply. If the income accrues to a person other than the performer, it remains taxable in the State of performance. These rules do not apply when the performer's visit is wholly or substantially funded from the public funds of the other Contracting State or its subdivisions.
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