Taxation of entertainers and sportspersons: income from performances abroad may be taxed where the activities occur. Income of entertainers and sports persons from personal activities exercised in the other Contracting State may be taxed in that State. Income that accrues to another person for those activities may also be taxed in the State where the activities are exercised. An exception applies where the visit is substantially supported by public funds of one or both Contracting States or their subdivisions or local authorities; then the income is taxable only in the entertainer's or sportsperson's State of residence.
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 entertainers and sportspersons: income from performances abroad may be taxed where the activities occur.
Income of entertainers and sports persons from personal activities exercised in the other Contracting State may be taxed in that State. Income that accrues to another person for those activities may also be taxed in the State where the activities are exercised. An exception applies where the visit is substantially supported by public funds of one or both Contracting States or their subdivisions or local authorities; then the income is taxable only in the entertainer's or sportsperson's State of residence.
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