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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.


Artists and Athletes

(1) Notwithstanding the provisions of Articles 15 and 16 hereof, the income gained by a resident in a Contracting State, as an artiste in cinema, theatre, radio or television, or as a musician or an athlete, from his/her personal activities done in the other Contracting State may be taxed in the other Contracting State.

(2) If the income of activities performed by an artiste or athlete in his capacity is not given to the artiste or the athlete himself, but is given to another person; such income, as exemption from the provisions of Articles 8, 15 and 16 herein, may be taxed in the Contracting State in which the activities of the artiste or athlete are performed.