Artist and athlete taxation permits source-state taxation of performance income by residents abroad, where public-funding exceptions apply.

Income earned by an entertainer or athlete from personal performances in the other Contracting State may be taxed in the State where the activities are exercised, including where the income accrues to a third party rather than to the performer personally; this source-state taxing entitlement is negated if the performer's visit is wholly or substantially supported from the public funds of the host State or its political subdivisions, statutory bodies or local authorities.

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