Taxation of entertainers: income from performances in another State may be taxed there unless publicly funded. Income of a resident entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in that other State; this applies whether the income accrues to the performer or to a third person. Exceptions: where the performer is supported wholly or substantially from the public funds of the resident State, the income is taxable only in the resident State; where income accruing to a third person is supported wholly or substantially from the public funds of the State of performance, that State alone may tax it.
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: income from performances in another State may be taxed there unless publicly funded.
Income of a resident entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in that other State; this applies whether the income accrues to the performer or to a third person. Exceptions: where the performer is supported wholly or substantially from the public funds of the resident State, the income is taxable only in the resident State; where income accruing to a third person is supported wholly or substantially from the public funds of the State of performance, that State alone may tax it.
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