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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.


Artists and Athletes

(1) Notwithstanding the provisions of Articles 14 and 15 of this Convention, income derived by a resident of a Contracting State in his capacity as a member of the arts, such as a theatre, film, radio or television artiste, or a musician, or in his capacity 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 athlete in his own capacity, accrues not to the artiste or athletes himself but to another person, such income, notwithstanding the provisions of Articles 7 and 14 of this Convention, may be taxed in the Contracting State in which the activities of artiste or athlete are exercised.

(3) Paragraphs (1) and (2) do not apply to income derived from the activity of artists or athletes performed in a Contracting State if the stay in that State is wholly or predominantly financed from public funds of the other state, one of its states or localities or by an institution recognized by this State as philanthropic. In this case, earnings can only be taxed in the other Contracting State.