Taxation of entertainers: performance income in another state may be taxed there, with public funds exceptions limiting source taxation. Income of entertainers and sportspersons from personal activities performed in the other Contracting State may be taxed in that other State, including where such income accrues to a person other than the performer. If the activities in the other State are supported wholly or substantially from the performer's residence State public funds, the income is taxable only in the residence State. Similarly, where income accrued to another person is supported wholly or substantially from the other State's public funds, that income is taxable only in that other 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 entertainers: performance income in another state may be taxed there, with public funds exceptions limiting source taxation.
Income of entertainers and sportspersons from personal activities performed in the other Contracting State may be taxed in that other State, including where such income accrues to a person other than the performer. If the activities in the other State are supported wholly or substantially from the performer's residence State public funds, the income is taxable only in the residence State. Similarly, where income accrued to another person is supported wholly or substantially from the other State's public funds, that income is taxable only in that other State.
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