Taxation of entertainers and athletes permits source-state taxation except where activities are funded wholly or substantially by public funds.

Income of resident entertainers and athletes from personal activities in the other Contracting State may be taxed in the State where activities are exercised; income accruing to another person may also be taxed there. Exceptions: if the activities are supported wholly or substantially from the performer's State public funds, taxation is limited to the performer's State; similarly, if income accrues to a resident of the State of performance who is supported wholly or substantially from that State's public funds, taxation is limited to that State.

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