Taxation of artistes and sports persons: performance income may be taxed in the State where activities occur, with public funding exemptions. Income of a resident entertainer or sportsperson from personal performances in the other Contracting State may be taxed in the State where the activities are exercised, and this applies whether the income accrues to the performer or to another person. Income so attributable is exempt in the performance State when the activity is financed from public funds or carried out under a cultural cooperation agreement. Where the recipient of performance income is supported wholly or substantially from public funds of the other State, that income is taxable only in that other State.
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 artistes and sports persons: performance income may be taxed in the State where activities occur, with public funding exemptions.
Income of a resident entertainer or sportsperson from personal performances in the other Contracting State may be taxed in the State where the activities are exercised, and this applies whether the income accrues to the performer or to another person. Income so attributable is exempt in the performance State when the activity is financed from public funds or carried out under a cultural cooperation agreement. Where the recipient of performance income is supported wholly or substantially from public funds of the other State, that income is taxable only in that other State.
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