Taxation of artistes and athletes: source-based taxing right for performance income and enterprise profits, with public-funds exemption. Income of public entertainers and athletes from personal performances may be taxed in the Contracting State where the activities are exercised, overriding other treaty articles; where services are provided by an enterprise of the other Contracting State, the profits of that enterprise from providing those services may also be taxed in the State where performed; both rules do not apply if the visit is financed wholly or substantially from the other Contracting State's public funds.
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Provisions expressly mentioned in the judgment/order text.
Taxation of artistes and athletes: source-based taxing right for performance income and enterprise profits, with public-funds exemption.
Income of public entertainers and athletes from personal performances may be taxed in the Contracting State where the activities are exercised, overriding other treaty articles; where services are provided by an enterprise of the other Contracting State, the profits of that enterprise from providing those services may also be taxed in the State where performed; both rules do not apply if the visit is financed wholly or substantially from the other Contracting State's public funds.
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