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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