Taxation of entertainers' and athletes' income in the source State, with public funding exceptions limiting residence taxation. Income from personal activities performed by entertainers or athletes in the other Contracting State may be taxed in the State where those activities are exercised, whether the income accrues to the performer or to another person. Exceptions: where the performer's activities in the other State are supported wholly or substantially from the public funds of the resident State, taxation is limited to the resident State; similarly, if the recipient of the income is supported wholly or substantially from the public funds of the State where the activities occur, that State alone may tax the income.
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 in the source State, with public funding exceptions limiting residence taxation.
Income from personal activities performed by entertainers or athletes in the other Contracting State may be taxed in the State where those activities are exercised, whether the income accrues to the performer or to another person. Exceptions: where the performer's activities in the other State are supported wholly or substantially from the public funds of the resident State, taxation is limited to the resident State; similarly, if the recipient of the income is supported wholly or substantially from the public funds of the State where the activities occur, that State alone may tax the income.
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