Taxation of visiting entertainers and sportsmen: source State may tax performance income, subject to public funding exemption. Income of visiting entertainers and sportsmen from personal activities performed in the other Contracting State may be taxed in the State where the activities are exercised; this applies whether the income accrues to the performer or to another person. The source-taxation rule does not apply where the visit is wholly or substantially supported from the public funds of the performer's home State, its political subdivisions, local authorities or statutory bodies.
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 visiting entertainers and sportsmen: source State may tax performance income, subject to public funding exemption.
Income of visiting entertainers and sportsmen from personal activities performed in the other Contracting State may be taxed in the State where the activities are exercised; this applies whether the income accrues to the performer or to another person. The source-taxation rule does not apply where the visit is wholly or substantially supported from the public funds of the performer's home State, its political subdivisions, local authorities or statutory bodies.
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