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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 Sportspersons

(1) Notwithstanding the provisions of Articles 14 and 15, the income that a resident of a Contracting State earns from his personal activities exercised in the other Contracting State as a theater artist, or a stage-show entertainer, as a cinema, radio or television star or a musician or sportsperson, shall be taxable in that other State where such activities are performed.

(2) The provisions of paragraph (1) of this Article shall not apply to income received in a Contracting State by the persons referred to in said paragraph in their capacity as employees of non-profit organizations of the other Contracting State.

(3) The provisions of paragraph (1) of the present Article shall not apply to the income derived from activities which are a part of cultural exchanges established by cultural Conventions concluded between the two Contracting States.