Taxation of entertainers and athletes: source State may tax performance income unless the visit is state-funded by the other State. Income of public entertainers and athletes from their personal activities may be taxed only in the Contracting State where those activities are exercised, notwithstanding Articles 14 and 15. That income shall not be taxed in that State if the entertainer's or athlete's visit to the State is directly or indirectly supported, wholly or substantially, from the public funds of the other Contracting State. 'Public funds' means funds of a Contracting State, its political sub-divisions, or local or statutory authorities.
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 athletes: source State may tax performance income unless the visit is state-funded by the other State.
Income of public entertainers and athletes from their personal activities may be taxed only in the Contracting State where those activities are exercised, notwithstanding Articles 14 and 15. That income shall not be taxed in that State if the entertainer's or athlete's visit to the State is directly or indirectly supported, wholly or substantially, from the public funds of the other Contracting State. "Public funds" means funds of a Contracting State, its political sub-divisions, or local or statutory authorities.
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