Taxation of entertainers and athletes may occur in the State where performances take place, subject to cultural exchange exemptions. Income of a resident entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in the State where performed, but is exempt there if carried out pursuant to a Government-agreed special cultural exchange programme. The same rule applies where such income accrues to another person resident of the other Contracting State: it may be taxed in the State where performed, subject to exemption under the special cultural exchange programme.