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of <h1>Entertainers' and athletes' income from foreign activities may be taxed unless part of a government-approved cultural exchange program.</h1> Income earned by entertainers or athletes, who are residents of one contracting state, from activities performed in the other contracting state, may be taxed in the latter. However, if these activities are part of a cultural exchange program agreed upon by both governments, the income is exempt from tax in the host state. Additionally, if the income from these activities accrues to a third party residing in the entertainer's or athlete's home state, it may still be taxed in the host state, unless it is part of a government-approved cultural exchange program.
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