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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 theatre, motion picture, radio or television artist or as a musician or 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 entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14, and 15 of this Convention be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.

(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to income from activities performed by artistes or athletes in a Contracting State if the visit to that State is wholly or mainly financed by public funds of the other Contracting State, one of its territories or political subdivisions, one of its local authorities or, in the scope of an Agreement between the two Contracting States, or by an organization which in that other State is recognized as a charitable organization. In this case, the income shall be taxable only in the Contracting State where the artist or athlete resides.