Taxation of performers: income from personal performances may be taxed in the State where activities are exercised. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that State notwithstanding Articles 14 and 15. Where such income accrues to another person rather than the performer, that income may also be taxed in the Contracting State in which the activities are exercised, notwithstanding Articles 7, 14 and 15.
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 performers: income from personal performances may be taxed in the State where activities are exercised.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that State notwithstanding Articles 14 and 15. Where such income accrues to another person rather than the performer, that income may also be taxed in the Contracting State in which the activities are exercised, notwithstanding Articles 7, 14 and 15.
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