Taxation of entertainers: income from personal performances may be taxed where the activities are exercised under the treaty.

Income earned by a resident entertainer or athlete from personal performances in the other Contracting State may be taxed in the State where the activities are exercised; where such income accrues to another person it may also be taxed in the State of performance. Exceptions: if the activities are financed wholly or substantially from the public funds of the performer's residence State, taxation is limited to the residence State; if the recipient is funded wholly or substantially from the public funds of the State of performance, taxation is limited to that State.

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