Taxation of entertainers' and athletes' income: activities taxed where performed unless supported substantially by home public funds. Income of entertainers and athletes from personal performances in the other Contracting State may be taxed in the State where the activities are performed, including when the income accrues to a third person. Where the activities are supported wholly or substantially from the public funds of the performer's residence State, taxation is confined to the residence State; conversely, income accruing to a third person supported wholly or substantially from the public funds of the State where activities occur is taxable only in that 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 entertainers' and athletes' income: activities taxed where performed unless supported substantially by home public funds.
Income of entertainers and athletes from personal performances in the other Contracting State may be taxed in the State where the activities are performed, including when the income accrues to a third person. Where the activities are supported wholly or substantially from the public funds of the performer's residence State, taxation is confined to the residence State; conversely, income accruing to a third person supported wholly or substantially from the public funds of the State where activities occur is taxable only in that State.
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