Article 18 - Entertainers and Athletes

Taxation of entertainers and athletes: source-state taxation allowed, with cultural exchange funding exemptions limiting source tax.

Income of a resident entertainer or athlete from activities exercised in the other Contracting State may be taxed in that other State, and income accruing to a third person from those activities may likewise be taxed in the State where the activities occur. Exceptions provide that where activities are part of a government cultural exchange programme substantially funded by the resident State or qualifying bodies, or reciprocally funded by the source State for its residents, such income is taxable only in the first-mentioned Contracting State, subject to competent authority certification for qualifying non-profit organisations.