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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 Sports

(1) Notwithstanding the provisions of Articles 14 and 15, 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 theatre artist of cinema, radio or television, or a musician, or as an athlete, are taxable in that other State.

(2) Where the income from activities performed by a performer or an athlete personally and in that capacity is attributed not to the artist or the sportsperson himself but to another person, these are taxable, notwithstanding the provisions of the articles 7, 14 and 15, in the Contracting State where the activities of the entertainer or sportsman are carried on.

(3) Notwithstanding the provisions of paragraphs (1) and (2) of this Article, income derived from the activities referred to in paragraph (1) in the context of cultural or sports exchange program approved and financed in whole or in part by the governments of the Contracting States or by their political subdivisions or local authorities and which are not carried on for profit, are exempt from taxation in the Contracting State where its activities are carried out.