Taxation of entertainers and sportspersons: source State may tax performance income, with public-funded visit exception. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State; income accruing to a third person may also be taxed in the State where the activities are exercised; however, if the visit is substantially supported by public funds of one or both Contracting States or their political sub divisions or local authorities, the income is taxable only in the State of residence.
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, with public-funded visit exception.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State; income accruing to a third person may also be taxed in the State where the activities are exercised; however, if the visit is substantially supported by public funds of one or both Contracting States or their political sub divisions or local authorities, the income is taxable only in the State of residence.
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