Taxation of entertainers and sportspersons: income from performances may be taxed where activities are performed, subject to public funding exception. Income earned by a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in the State where the activities are performed; income that accrues to another person for those activities is similarly taxable in the activity State. Activities substantially supported by public funds are excepted, in which event the income is taxable only in the performer's 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 from performances may be taxed where activities are performed, subject to public funding exception.
Income earned by a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in the State where the activities are performed; income that accrues to another person for those activities is similarly taxable in the activity State. Activities substantially supported by public funds are excepted, in which event the income is taxable only in the performer's State of residence.
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