Taxation of artistes and sportspersons: source-state taxation allowed for performance income, with public-funded exception limiting residence taxation. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State; income that accrues to another person may likewise be taxed in the State where the activities are exercised notwithstanding other treaty provisions. Where such activities are substantially supported by public funds of one or both Contracting States or their subdivisions, 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 artistes and sportspersons: source-state taxation allowed for performance income, with public-funded exception limiting residence taxation.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State; income that accrues to another person may likewise be taxed in the State where the activities are exercised notwithstanding other treaty provisions. Where such activities are substantially supported by public funds of one or both Contracting States or their subdivisions, the income is taxable only in the State of residence.
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