Taxation of artistes and sportspersons: income from performances in another State may be taxed there, subject to public funding exceptions. Income of an entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State; where such income accrues to a third person it may also be taxed in the State where the activities occur. Exceptions: if the activities are supported wholly or substantially from the performer's State public funds, the income is taxable only in the performer's State; likewise, if the third person is supported wholly or substantially from that other State's public funds, the income is taxable only in that other State.
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Provisions expressly mentioned in the judgment/order text.
Taxation of artistes and sportspersons: income from performances in another State may be taxed there, subject to public funding exceptions.
Income of an entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State; where such income accrues to a third person it may also be taxed in the State where the activities occur. Exceptions: if the activities are supported wholly or substantially from the performer's State public funds, the income is taxable only in the performer's State; likewise, if the third person is supported wholly or substantially from that other State's public funds, the income is taxable only in that other State.
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