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        DTAA

        Article 18 - Income earned by entertainers and athletes

        France

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        Taxation of entertainers and athletes permits source state taxation of performance income and third party receipts, with public funding exceptions. Income from personal activities of entertainers and athletes is taxable in the State where the activities are exercised; if income accrues to a third person it may likewise be taxed in the State of performance. Exceptions: where the performer is funded wholly or substantially by public funds of the resident State, only the State of residence taxes the income; and where a third person recipient is funded wholly or substantially by public funds of the State of performance, only that State taxes 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 permits source state taxation of performance income and third party receipts, with public funding exceptions.

                                Income from personal activities of entertainers and athletes is taxable in the State where the activities are exercised; if income accrues to a third person it may likewise be taxed in the State of performance. Exceptions: where the performer is funded wholly or substantially by public funds of the resident State, only the State of residence taxes the income; and where a third person recipient is funded wholly or substantially by public funds of the State of performance, only that State taxes the income.


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