Taxation of entertainers and sportspersons: source state may tax earnings from performances, with a public funding exception. Income earned by a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed; the same applies where such income accrues to another person. An exception excludes source-state taxation if the visit is substantially supported by public funds of one or both Contracting States or their political subdivisions or local authorities, in which case taxation is confined to the performer's 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 entertainers and sportspersons: source state may tax earnings from performances, with a public funding exception.
Income earned by a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed; the same applies where such income accrues to another person. An exception excludes source-state taxation if the visit is substantially supported by public funds of one or both Contracting States or their political subdivisions or local authorities, in which case taxation is confined to the performer's State of residence.
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