Taxation of entertainers and sportspersons: income may be taxed where performances occur unless visit is publicly funded. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, and income accruing to a third person for such activities may likewise be taxed in the State where the activities are exercised, notwithstanding other allocation rules; however, if the visit is substantially supported by public funds or the activity is within a cultural or sports cooperation agreement, the income is taxable only in the State of residence.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of entertainers and sportspersons: income may be taxed where performances occur unless visit is publicly funded.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State, and income accruing to a third person for such activities may likewise be taxed in the State where the activities are exercised, notwithstanding other allocation rules; however, if the visit is substantially supported by public funds or the activity is within a cultural or sports cooperation agreement, the income is taxable only in the State of residence.
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