Taxation of artistes and sportspersons: source-state taxing right for personal activities, subject to public fund exceptions. Income of an artiste or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where activities are performed, notwithstanding Articles 14 and 15; where such income accrues to another person, it may be taxed in the State where the activities occur notwithstanding Articles 7, 14 and 15, subject to exceptions when activities or the recipient are supported wholly or substantially from public funds of a Contracting State.
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 taxing right for personal activities, subject to public fund exceptions.
Income of an artiste or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where activities are performed, notwithstanding Articles 14 and 15; where such income accrues to another person, it may be taxed in the State where the activities occur notwithstanding Articles 7, 14 and 15, subject to exceptions when activities or the recipient are supported wholly or substantially from public funds of a Contracting State.
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