Taxation of entertainers: source-state may tax performers' earnings from activities in that State, subject to a 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, whether earned directly or accruing to another person, notwithstanding Articles 7, 15 and 16; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is 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: source-state may tax performers' earnings from activities in that State, subject to a 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, whether earned directly or accruing to another person, notwithstanding Articles 7, 15 and 16; however, if the activities are substantially supported by public funds of a Contracting State or its subdivisions, the income is taxable only in the State of residence.
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