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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 Sportspersons

(1) Notwithstanding provisions of Articles 7 and 14, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, musician, or sportsmen, 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 or a sportsperson in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the Contracting State in which the activities of the entertainer or sportsmen are exercised.

(3) Paragraphs (1) and (2) shall not apply to income of artists or sportspersons for their activities carried out in one Contracting State if the stay in this State has been financed fully or to a significant degree from out of public funds of one or both of the Contracting State or by one of its states or provinces or one of its political subdivisions, or by a government organisation or an organisation generally recognised as non-profit organisation. In such a case, income may be taxed only in that Contracting State of which the person is resident.