Source taxation of artistes and sportspersons permits taxing performance income where activities are exercised, subject to a public funding exception. Income of an artiste or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State; if the income accrues to another person it may also be taxed in the State where the activities are exercised. The foregoing does not apply when the visit is wholly or substantially supported by public funds of one or both Contracting States or their subdivisions, in which case the income is taxable only in the State of residence.