Taxation of entertainers and athletes: income is generally taxable in the State of performance, subject to public funding and cultural exchange exceptions. Income of residents as entertainers or athletes from personal activities in the other Contracting State is generally taxable in the State where the activities are exercised, including where income accrues to a third person. Exceptions: activities within a bilateral cultural exchange or substantially supported from the performer's State public funds are taxable only in the performer's State; income accruing to a third person supported largely from the public funds of the State of activity is taxable only in that 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 and athletes: income is generally taxable in the State of performance, subject to public funding and cultural exchange exceptions.
Income of residents as entertainers or athletes from personal activities in the other Contracting State is generally taxable in the State where the activities are exercised, including where income accrues to a third person. Exceptions: activities within a bilateral cultural exchange or substantially supported from the performer's State public funds are taxable only in the performer's State; income accruing to a third person supported largely from the public funds of the State of activity is taxable only in that State.
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