Taxation of artistes and sportspersons: income from personal activities may be taxed where performed, subject to public funding exception.

Article 17 permits the State where personal activities of artistes or sportspersons are exercised to tax income from those activities, and also permits taxation where such income accrues to a third person, notwithstanding other treaty provisions; however, if the visit is substantially supported by public funds of the State of residence or its subdivisions, the income is taxable only in the State of residence.

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