Taxation of entertainers and athletes: source State may tax performance income, with narrow public funded exchange exemptions. Income of entertainers and athletes is taxable in the State where personal performances are exercised, even if receipts accrue to another person, except where the activities are part of a mutually agreed cultural or sports exchange programme supported wholly or substantially from the public funds of the performer's State or, where applicable, the other State; in those cases taxation is confined to the resident State or to the State providing the 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: source State may tax performance income, with narrow public funded exchange exemptions.
Income of entertainers and athletes is taxable in the State where personal performances are exercised, even if receipts accrue to another person, except where the activities are part of a mutually agreed cultural or sports exchange programme supported wholly or substantially from the public funds of the performer's State or, where applicable, the other State; in those cases taxation is confined to the resident State or to the State providing the public funds.
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