Taxation of artistes and athletes: source state may tax income from personal activities exercised within its territory. Income earned by public entertainers and athletes from their personal activities is subject to taxation by the Contracting State in which those activities are performed; this applies to performers such as theatre, motion picture, radio or television artistes and musicians, and to athletes in respect of earnings derived from their activities as such, notwithstanding other treaty provisions.
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 artistes and athletes: source state may tax income from personal activities exercised within its territory.
Income earned by public entertainers and athletes from their personal activities is subject to taxation by the Contracting State in which those activities are performed; this applies to performers such as theatre, motion picture, radio or television artistes and musicians, and to athletes in respect of earnings derived from their activities as such, notwithstanding other treaty provisions.
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