Taxation of artistes and athletes: income from personal performances generally taxable where activities are exercised, subject to public funds exceptions.

Income from personal activities of public entertainers and athletes may be taxed in the State where the activities are exercised, including where income accrues to another person, notwithstanding other treaty rules; however, if the activities or the recipient are supported wholly or substantially from the public funds of a Contracting State, taxation is restricted to that supporting Contracting State.

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