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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.

ARTICLE 17

Artistes and Sportsmen

(1) Notwithstanding the provisions of Article 8 and 15, 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 a sportsman, from his 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 sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 8 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2) of this Article, income mentioned in this Article accruing to an artiste or sportsman resident of a Contracting State shall be exempt from tax in the other Contracting State, in which the activity of the entertainer or sportsman is exercised, provided that this activity is supported in a considerable part out of public funds of the first-mentioned State. In such a case, the income shall be taxable only in the Contracting State of which the artiste or sportsman is a resident.