Taxation of entertainers' income: source-state may tax performance-linked earnings when presence exceeds a short threshold. Income of public entertainers and athletes arising from their personal activities may be taxed in the Contracting State where those activities are exercised; this special source-based rule applies only if those activities are carried out in that State for an aggregate period exceeding 15 days in the relevant previous or fiscal year and only to income attributable to the activities performed there.
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' income: source-state may tax performance-linked earnings when presence exceeds a short threshold.
Income of public entertainers and athletes arising from their personal activities may be taxed in the Contracting State where those activities are exercised; this special source-based rule applies only if those activities are carried out in that State for an aggregate period exceeding 15 days in the relevant previous or fiscal year and only to income attributable to the activities performed there.
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