Taxation of entertainers and sportspersons: source state may tax performance income, subject to public funding exceptions. Income of entertainers and sportspersons from personal activities performed in the other Contracting State may be taxed in that other State, including where income accrues to another person; however, if the activities or the recipient are supported wholly or substantially from the public funds of a Contracting State (including its political sub divisions or local authorities), taxation is confined to the supporting State.
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Provisions expressly mentioned in the judgment/order text.
Taxation of entertainers and sportspersons: source state may tax performance income, subject to public funding exceptions.
Income of entertainers and sportspersons from personal activities performed in the other Contracting State may be taxed in that other State, including where income accrues to another person; however, if the activities or the recipient are supported wholly or substantially from the public funds of a Contracting State (including its political sub divisions or local authorities), taxation is confined to the supporting State.
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