Taxation of entertainers and sportspersons: source State may tax performance income, subject to public funds exceptions. Income of resident entertainers or sportspersons from personal activities exercised in the other Contracting State may be taxed by that other State, and the same applies where such income accrues to another person; however, such income is taxable only in the State of residence if the activities abroad are supported wholly or substantially from the public funds of the residence State, and where income accrues to a third person it is taxable only in the other State if that recipient is supported wholly or substantially from the public funds of 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 and sportspersons: source State may tax performance income, subject to public funds exceptions.
Income of resident entertainers or sportspersons from personal activities exercised in the other Contracting State may be taxed by that other State, and the same applies where such income accrues to another person; however, such income is taxable only in the State of residence if the activities abroad are supported wholly or substantially from the public funds of the residence State, and where income accrues to a third person it is taxable only in the other State if that recipient is supported wholly or substantially from the public funds of that other State.
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