Taxation of artistes and sports persons: source State may tax performance income, with exceptions for public funding or cultural agreements. Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed, and the same applies where such income accrues to a third party; however, this source taxation does not apply if the activities are substantially supported by public funds or take place under a cultural agreement, in which case taxation is limited to the State of residence.
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Provisions expressly mentioned in the judgment/order text.
Taxation of artistes and sports persons: source State may tax performance income, with exceptions for public funding or cultural agreements.
Income of a resident entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in the State where the activities are performed, and the same applies where such income accrues to a third party; however, this source taxation does not apply if the activities are substantially supported by public funds or take place under a cultural agreement, in which case taxation is limited to the State of residence.
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