Taxation of entertainers: source state may tax performance income unless visit is publicly funded or no profit participation. Income derived by a resident entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in that source State. If income accrues to another person providing the activities, it may still be taxed in the source State unless the performer and related persons do not participate in that other person's profits, including deferred remuneration, bonuses, fees, dividends, partnership distributions or other distributions. The source-state taxing right does not apply where the visit is substantially supported from 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: source state may tax performance income unless visit is publicly funded or no profit participation.
Income derived by a resident entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in that source State. If income accrues to another person providing the activities, it may still be taxed in the source State unless the performer and related persons do not participate in that other person's profits, including deferred remuneration, bonuses, fees, dividends, partnership distributions or other distributions. The source-state taxing right does not apply where the visit is substantially supported from public funds.
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