Taxation of artistes and sportspersons: performing income may be taxed where activities occur, subject to public funding exceptions. Income earned by a resident artiste or sportsperson from personal activities in the other Contracting State may be taxed in the State where the activities are exercised, including where such income accrues to a third person. However, if the activities in the other State are supported wholly or substantially from the performer's State of residence public funds, taxation is confined to the State of residence; likewise, income accruing to a third person is taxable only in the other State if that third person is supported wholly or substantially from that other State's public funds.
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 sportspersons: performing income may be taxed where activities occur, subject to public funding exceptions.
Income earned by a resident artiste or sportsperson from personal activities in the other Contracting State may be taxed in the State where the activities are exercised, including where such income accrues to a third person. However, if the activities in the other State are supported wholly or substantially from the performer's State of residence public funds, taxation is confined to the State of residence; likewise, income accruing to a third person is taxable only in the other State if that third person is supported wholly or substantially from that other State's public funds.
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