Source taxation of entertainers' and sportspersons' income permitted; public-funding support makes income taxable only in resident state. Income earned by a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State; income that accrues to a third person is likewise taxable in the source State. The source-country taxing right is excluded where the activities are substantially supported by public funds, in which case the income is taxable only in the Contracting 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.
Source taxation of entertainers' and sportspersons' income permitted; public-funding support makes income taxable only in resident state.
Income earned by a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State; income that accrues to a third person is likewise taxable in the source State. The source-country taxing right is excluded where the activities are substantially supported by public funds, in which case the income is taxable only in the Contracting State of residence.
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