Taxation of entertainers and athletes: income from performances may be taxed in the state where the activities occur unless publicly funded. Income of a resident earned from personal performances as an entertainer or athlete in the other Contracting State may be taxed in that State. If the income accrues to another person providing the activities, it may be taxed in the source State unless it is shown the performer or related persons do not participate in the recipient's profits, including deferred remuneration or distributions. The provisions do not apply where the visit is substantially supported from the other State's public funds.
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 from performances may be taxed in the state where the activities occur unless publicly funded.
Income of a resident earned from personal performances as an entertainer or athlete in the other Contracting State may be taxed in that State. If the income accrues to another person providing the activities, it may be taxed in the source State unless it is shown the performer or related persons do not participate in the recipient's profits, including deferred remuneration or distributions. The provisions do not apply where the visit is substantially supported from the other State's public funds.
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