Taxation of entertainers and athletes: source State may tax performance income, with public funding and cultural exchange exceptions. Article 17 provides that income of a resident entertainer or athlete from personal activities in the other Contracting State may be taxed in that State; income accruing to another person from those activities may likewise be taxed in the State where the activities are performed. Exceptions allocate taxation to the residence State where activities are supported wholly or substantially from the residence State's public funds or undertaken under an agreed cultural exchange programme, and a corresponding rule applies when a third person supported by public funds or participating in such a programme receives 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: source State may tax performance income, with public funding and cultural exchange exceptions.
Article 17 provides that income of a resident entertainer or athlete from personal activities in the other Contracting State may be taxed in that State; income accruing to another person from those activities may likewise be taxed in the State where the activities are performed. Exceptions allocate taxation to the residence State where activities are supported wholly or substantially from the residence State's public funds or undertaken under an agreed cultural exchange programme, and a corresponding rule applies when a third person supported by public funds or participating in such a programme receives the income.
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