Taxation of entertainers and sportspersons: source State may tax performance income, with a public funding exception preserving residence taxation. Income of a resident entertainer or sportsperson from personal activities performed in the other Contracting State may be taxed in that other State, ... Summary
Taxation of entertainers and sportspersons: source State may tax performance income, with a public funding exception preserving residence taxation.
Income of a resident entertainer or sportsperson from personal activities performed in the other Contracting State may be taxed in that other State, including where such income accrues to a third party rather than the performer. This source State taxing right applies notwithstanding Articles 7, 14 and 15. However, if the visit to the other State is substantially supported by public funds of the performer's State of residence or its subdivisions, the income is taxable only in the State of residence.
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