Taxation of entertainers and sportsmen: source State may tax income from personal performances, subject to treaty exception. Article 17 permits the Contracting State where personal activities of an entertainer or sportsman are exercised to tax income derived by a resident of the other State from those activities. Income accruing to a third person in respect of such activities may also be taxed in the State where the activities occur. However, income from activities performed during a visit wholly or substantially financed by the other State or its political subdivisions is not taxable in the source State under paragraph 1.
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 sportsmen: source State may tax income from personal performances, subject to treaty exception.
Article 17 permits the Contracting State where personal activities of an entertainer or sportsman are exercised to tax income derived by a resident of the other State from those activities. Income accruing to a third person in respect of such activities may also be taxed in the State where the activities occur. However, income from activities performed during a visit wholly or substantially financed by the other State or its political subdivisions is not taxable in the source State under paragraph 1.
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