Taxation of artistes and sportspersons: income from personal activities may be taxed where performed, subject to exchange program exception. Income of resident artistes and sports persons from personal activities exercised in the other Contracting State may be taxed in the State where the activities are exercised, and that taxing right applies even if such income accrues to another person rather than to the artiste or sportsperson; however, income from activities undertaken within a mutually approved cultural or sports exchange program is taxable only in the resident State.
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 artistes and sportspersons: income from personal activities may be taxed where performed, subject to exchange program exception.
Income of resident artistes and sports persons from personal activities exercised in the other Contracting State may be taxed in the State where the activities are exercised, and that taxing right applies even if such income accrues to another person rather than to the artiste or sportsperson; however, income from activities undertaken within a mutually approved cultural or sports exchange program is taxable only in the resident State.
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