background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 16

Artists, Athletes and Models

(1) Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of a Contracting State from his personal activities exercised in the other Contracting State as an entertainer, such as a theater artist, film, radio or television artist, or as a musician, or as an athlete or model may be taxed in that other State.

(2) Notwithstanding the provisions of Articles 7, 12, 14 and 20, when an artist, an athlete or a model resident of a Contracting State, derives income from the other Contracting corresponding to services that are not independent to his professional reputation, such income may be taxed in that other State.

(3) Where the income referred to in paragraph (1) accrues not to the artist, athlete or model him or herself but to another person, that income may, notwithstanding the provisions of Articles 7, 12, 14 and 20, be taxed in the Contracting State in which it arises.

(4) Notwithstanding the provisions of paragraph (1), income derived by a resident of a Contracting State from his personal activities exercised in the other Contracting State as an artist, athlete or model shall be taxable only in the first mentioned State where such activities in the other State are financed mainly by public funds from the first mentioned State or one of its local authority or statutory body governed by public law.

(5) Notwithstanding the provisions of paragraph (2), where the income from activities that a resident of a Contracting State, as an artist, athlete or model, carries on personally and in that capacity in the other Contracting State, accrues not to the artist, athlete or model him or herself but to another person, whether or not a resident of a Contracting State, such income may, notwithstanding the provisions of Articles 7, 12, 14 and 20, be only taxed in the first mentioned State when, in respect of these activities this other person is primarily financed by public funds of the first mentioned State one of its local authority or statutory body governed by public law.