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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 Athletes

(1) Notwithstanding the provisions of Articles 14 and 15, income derived by professional entertainers, such as theatre, motion picture, radio or television artistes, and musicians, or by athletes, from their personal activities as such, may be taxed in the Contracting State in which such activities are exercised.

(2) Where income in respect of personal activities exercised by an entertainer or an athlete accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the State in which the activities of the entertainer or athlete are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2), income derived from activities of the kind referred to therein may not be taxed in the State in which the entertainer or athlete exercises his activities if the entertainer or athlete performs under the cultural exchange arrangements agreed by the Contracting States.