Income earned by entertainers and athletes
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....usician or as an athlete, from his personal activities as such exercised in the other Contracting State may be taxed in that other State. 2. While income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 13 and ....
TaxTMI