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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, income derived by a resident of  a Contracting State, as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or 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 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 that artiste or athlete are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2), income referred to in this Article shall not be taxed in a Contracting State in which such activities are exercised, if such activities are financed substantially from public funds of that State or of the other Contracting State or if such activities are exercised in the other Contracting State in accordance with the cultural agreements between the Contracting States. In such case the income may be taxed in the Contracting State of which the person is resident.