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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 Athletes

(1) Notwithstanding the provisions of Articles 14 and 15 of this Convention, income derived by a resident of a Contracting State in his capacity as a member of the arts, such as a theatre, film, radio or television artiste, or a musician, or in his capacity as an athlete, 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 artiste or athlete in his own capacity, accrues not to the artiste or athletes himself but to another person, such income, notwithstanding the provisions of Articles 7, 14 and 15 of this Convention, may be taxed in the Contracting State in which the activities of artiste or athlete are exercised.

(3) Notwithstanding the provisions of abovementioned paragraph (1), the income derived from activities exercised by an artist or athlete resident in a Contracting state and performing in the other Contracting state shall be taxed only in the first mentioned Contracting State if the activities performed in the other Contracting state received wholly or partial subsidy from the first mentioned Contracting state, any of its political divisions or local authorities.

(4) Notwithstanding the provisions of paragraph (2) and Articles 7, 14 and 15 of this Convention, the income derived from activities exercised by an artist or athlete in a Contracting state are not given to the artist or athlete but to another person, such income shall be taxable only in the other contacting state if this person receives substantial subsidy from the other Contracting, any of its political divisions or local authorities.