Taxation of entertainers' income can lie with the source State, subject to a public funding exception favoring residence taxation.

Income derived by residents as entertainers from personal activities exercised in the other Contracting State may be taxed in that other State, including where such income accrues to another person; however, if those activities or the third party's support are wholly or substantially financed from the public funds of a Contracting State (including its sub divisions or local authorities), the income is taxable only in the State providing such public funds.

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