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.
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 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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