Taxation of entertainers and athletes: State of performance may tax earnings, with threshold, attribution, and public fund exemptions.

Income derived by a resident as an entertainer or athlete from personal activities exercised in the other Contracting State may be taxed in the State of performance, subject to an exemption where net income after deductible visit and performance expenses does not exceed a specified monetary threshold; the threshold may be adjusted by mutual agreement. If such income accrues to another person, that income may be taxed in the State of performance unless it is shown that the entertainer, athlete or related persons do not participate in the profits of that other person. Visits supported wholly or substantially from public funds are exempt from taxation in the State of performance.

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