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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 musician, a theatre, motion picture, radio or television artiste, or as an athlete, from his personal activities exercised as such 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 the artiste or athlete are exercised.

(3) Paragraphs (1) and (2) of this Article shall not apply to income of entertainers or athletes that are derived from activities in a Contracting State in case the presence in such State is financed entirely or to a significant degree by public funds of one or both Contracting States, one of its states/provinces, or one of its political subdivisions, or by a government entity or an entity that is recognized as a non-profit organization.