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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.


Entertainers and Sportspersons

(1) Notwithstanding the provisions of Articles 7 and 14, 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 sportsperson, from its 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 in its capacity as such accrues not to the entertainer or sportsperson itself but to another person, that income may, notwithstanding, the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.

(3) Notwithstanding the provisions of paragraphs 1 and 2, income derived from the activities exercises by the entertainers or sportspersons in a Contracting State where the visit to that State is financed from public funds of the other State, a local government, local authority, or an administrative territorial unit thereof or by a public agency of them and the activity is carried out other than for the purpose of profit shall be exempt from tax in the Contracting State in which these activities are exercised.