Taxation of entertainers and athletes: income from performances abroad may be taxed by source state, subject to public funding exception. Income of a resident entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in the State of performance. Payments that accrue to another person for those activities may also be taxed in the State where the activities occur. If the activities abroad are supported wholly or substantially from the public funds of the performer's State of residence, including its political sub divisions or local authorities, the income is taxable only in the resident State.