background image
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.


Artistes and Athletes

(1) Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State from performing personal activities in the other Contracting State as an artiste (such as motion picture, theatrical, radio or television) or as musicians or as an athlete shall be taxable in the other Contracting State

(2) If the income from personal activities carried on by an artiste or an athlete in his own capacity, accrues not to the artiste or the athlete himself, but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15 be taxed in the Contracting State in which the activities of that artiste or athlete are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2) of this Article, the income of the activities performed by the artiste or athlete who is a resident of a Contracting State shall be taxable in that Contracting State only if these activities were performed in the other Contracting State in light of the cultural or athletic exchange agreed upon by both Contracting States.