Taxation of artistes and athletes permits source-state taxation, subject to exclusive residence-state treatment for publicly funded activities.

Article 17 permits the Contracting State where entertainers' and athletes' personal activities are exercised to tax the related income, including income accruing to another person. Public-funding exceptions apply where an entertainer or athlete's activities in the other Contracting State are wholly or substantially supported by public funds of the first-mentioned State, or where the other recipient is similarly supported. In those circumstances, exclusive taxing rights apply to the supporting Contracting State.

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