background image
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 15 and 16, income derived by a resident of a Contracting State as a theatre, motion picture, radio or television artiste, musician, athlete or other entertainer 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 referred to in paragraph (1) of this Article in his capacity as such accrues not to the entertainer himself but to another person, that income may, notwithstanding the provisions of Articles 7, 15 and 16, be taxed in the Contracting State in which the activities of the entertainer are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2) of this Article, income derived in respect of activities referred to in paragraph (1) of this Article within the framework of a cultural or sports exchange programme approved by both Contracting States shall be exempted from taxation in the Contracting State in which these activities are exercised.