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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 theatre, motion picture, radio or television artist, or a musician, or as an athlete, from his or her 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 an athlete in his capacity as such accrues not to the artiste or athlete him or herself 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) The provisions of paragraphs (1) and (2) shall not apply to income from activities of artistes or athletes in a Contracting State if the visit to that State is wholly or mainly financed by public funds of the other State Contracting State, of one of its Lander or of one of its political subdivisions, of one of their local authorities or of an organization recognized as being of public utility in that other State. In such case, the income is taxable only in the Contracting State in which the artiste or athlete resides.