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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.



(1) Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, a musician, or as a sportsperson, from that resident’s 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 entertainer or a sportsperson acting as such accrues not to the entertainer or sportsperson but to another person, that income, notwithstanding the provisions of Articles 7, 14 and 15, may be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.

(3) In accordance with what stated in paragraphs (1) and (2), the income gained by a resident in a Contracting State from activities he exercises in the other Contracting State shall be tax exempted in such Contracting State if the visit to that Contracting State is wholly or mainly supported by public funds of the Contracting State firstly-mentioned, any of municipalities or local authority thereof, or if such visit is made in accordance with cultural agreement or an agreement between the governments of the two Contracting States.

(4)4. Notwithstanding the provisions of paragraph (3), the income gained by an entertainer or athlete resident in a contracting state through activities exercised in the other contracting state based on his reputation as an entertainer or athlete may be taxable in the other contracting state.