Taxation of artistes and sportspersons: source state may tax income from personal activities exercised within its territory. Income derived by a resident who is an entertainer or sportsperson from personal activities performed in the other Contracting State may be taxed in that other State, and where such income accrues to another person it may nevertheless be taxed in the State in which the activities are exercised; however, activities substantially supported by public funds are taxable only in the State of residence of the entertainer or sportsperson.
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 may tax income from personal activities exercised within its territory.
Income derived by a resident who is an entertainer or sportsperson from personal activities performed in the other Contracting State may be taxed in that other State, and where such income accrues to another person it may nevertheless be taxed in the State in which the activities are exercised; however, activities substantially supported by public funds are taxable only in the State of residence of the entertainer or sportsperson.
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