ARTICLE 16
Artists and Athletes
(1) Irrespective of Articles 7 and 14, income drawn by a person resident in a Contracting State working in person as an artist, such as an artist of stage, film, radio or television, as well as musicians or athletes in the other Contracting State can be taxed in the other State. Irrespective of Article 12 as well, fees of any kind that is paid for the use of the name, or for the right to use the name, image or other personality rights of this person can also be taxed in the other State even if no employment activity is personally performed there. The like shall apply for income form the consent to recording and broadcast of artistic and athletic performances in radio and television.
(2) If income of the type described in Paragraph (1) of this Article are remunerated to a person other than the artist of athlete him/herself, their income can be taxed in the Contracting State from which they originate irrespective of Article 7, 12 and 14.