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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.


Artistes and Athletes

(1) Notwithstanding the provisions of Articles 7, 14 and 15 of this Convention, income derived by a resident of a Contracting State as an entertainer such as a musician or a theatre, motion picture, radio or television artiste, or as an athlete, from his personal activities exercised as such 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 an athlete in his capacity as such accrues not to the artiste or 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 the artiste or athlete are exercised.

(3) The provisions of paragraph (1) and (2) of this Article shall not apply to income derived from activities exercised in a Contracting State by an artiste or an athlete, if the visit to that State is wholly or mainly supported by that Contracting State itself, by one of its political subdivisions or local authorities, or by any legally recognized public institution recognized by that State. In this case, the income shall be taxable only in the Contracting State in which the artiste or athlete is a resident.