Artistes and Athletes
(1) Notwithstanding the provisions of Articles 14 and 15 of this Convention, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his or her personal activities as such exercised in the other Contracting State, may be taxed in that other State.
(2) Where income in respect of personal activities exercised by an artiste or an athlete in his capacity as such accrues not to the artiste or athlete him or herself but to another person, that income may, notwithstanding the provisions of Articles 7, 14, and 15 of this Convention, be taxed in the Contracting State in which the activities of the artiste or athlete are exercised. The provisions of this paragraph shall not apply if it is established that neither the artiste or athlete nor persons related thereto, participate directly in the profits of such person.
(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to income from activities performed in a Contracting State by artistes or athletes, when such income arises, for a substantial part, directly or indirectly, from public funds in the other Contracting State, its political subdivisions or local authorities thereof.