Taxation of entertainers' and sportspersons' income may be imposed in the State where activities occur, with public funds exceptions.

Income of an entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed, including where payment accrues to a third person. If the activities abroad are supported wholly or substantially from the public funds of the resident State, taxation is confined to the residence State; similarly, if a third person receiving the income is supported wholly or substantially from the public funds of the source State, that income is taxable only in the source State.

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