Taxation of entertainers and sportspersons in the source state is permitted despite residence, except where activities are publicly funded.

Income derived by a resident as an entertainer or sportsperson from personal activities exercised in the other Contracting State may be taxed in that other State; income accruing to another person for those activities may also be taxed in the State where the activities are exercised; these provisions do not apply if the activities are substantially supported by public funds, in which case the income is taxable only in the State of residence.

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