Taxation of entertainers and athletes: source State may tax performance income, subject to a public funding exception. Income of entertainers and athletes from personal activities may be taxed in the Contracting State where those activities are exercised notwithstanding provisions on independent or dependent personal services. If such income accrues to another person, it may still be taxed in the State where the activities occur notwithstanding business profits or personal services rules. The source taxing right is subject to an exception when the visit is directly or indirectly supported, wholly or substantially, from the public funds of the other Contracting State or its subdivisions or local authorities.
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 athletes: source State may tax performance income, subject to a public funding exception.
Income of entertainers and athletes from personal activities may be taxed in the Contracting State where those activities are exercised notwithstanding provisions on independent or dependent personal services. If such income accrues to another person, it may still be taxed in the State where the activities occur notwithstanding business profits or personal services rules. The source taxing right is subject to an exception when the visit is directly or indirectly supported, wholly or substantially, from the public funds of the other Contracting State or its subdivisions or local authorities.
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