Taxation of artistes and sportsmen: source State may tax performance income, including payments to third parties, subject to financing exception. Income derived by a resident as an artiste or a sportsman from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed. Income that accrues to another person from those activities may also be taxed in the State in which the activities are exercised. However, such income shall not be taxed in that State if the visit is wholly or substantially financed by the other Contracting State or by a political or administrative subdivision or local authority thereof.
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 artistes and sportsmen: source State may tax performance income, including payments to third parties, subject to financing exception.
Income derived by a resident as an artiste or a sportsman from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed. Income that accrues to another person from those activities may also be taxed in the State in which the activities are exercised. However, such income shall not be taxed in that State if the visit is wholly or substantially financed by the other Contracting State or by a political or administrative subdivision or local authority thereof.
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