Taxation of entertainers' and athletes' income: source State may tax performances, subject to public funds exceptions for exclusive residence taxation. Income of artistes and athletes from personal activities exercised in the other Contracting State may be taxed in that other State. If the income accrues to a third person, it may also be taxed where the activities occur. Exceptions: such income is taxable only in the residence State if the activities abroad are supported wholly or substantially from the residence State's public funds; conversely, income accruing to a third person is taxable only in the other State if that person is supported wholly or substantially from that other State's public funds.
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: source State may tax performances, subject to public funds exceptions for exclusive residence taxation.
Income of artistes and athletes from personal activities exercised in the other Contracting State may be taxed in that other State. If the income accrues to a third person, it may also be taxed where the activities occur. Exceptions: such income is taxable only in the residence State if the activities abroad are supported wholly or substantially from the residence State's public funds; conversely, income accruing to a third person is taxable only in the other State if that person is supported wholly or substantially from that other State's public funds.
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