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of <h1>Entertainers' and athletes' income taxed where activities occur, except for public-funded cultural or sports exchanges.</h1> Income earned by entertainers and athletes residing in one Contracting State from activities performed in the other Contracting State may be taxed in the latter. If such income accrues to another person, it may still be taxed where the activities occur. However, if these activities are part of a cultural or sports exchange program supported by public funds of the entertainer's or athlete's resident State, the income is taxable only in the resident State. Similarly, income accruing to another person under such programs is taxable only in the State where the activities are performed.
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