Taxation of entertainers and sportspersons: foreign State may tax performance income, except when visit is publicly funded. Income of a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State; income accruing to a third person for such activities may likewise be taxed in the State where the activities are exercised. These rules do not apply if the visit is substantially supported by public funds, in which case the income is taxable only in the State of residence.
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 entertainers and sportspersons: foreign State may tax performance income, except when visit is publicly funded.
Income of a resident entertainer or sportsperson from personal activities in the other Contracting State may be taxed in that other State; income accruing to a third person for such activities may likewise be taxed in the State where the activities are exercised. These rules do not apply if the visit is substantially supported by public funds, in which case the income is taxable only in the State of residence.
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