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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.

ARTICLE 16

Artistes and Sportspersons

(1) Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of a territory as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other territory, may be taxed in that other territory.

(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 sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, be taxed in the territory in which the activities of the entertainer or sportsperson are exercised.

(3) The provisions of paragraphs 1 and 2 shall not apply to income accruing from the exercise of activities by entertainers or sportspersons in a territory where the visit to that territory is financed entirely or mainly from public funds of the other territory or by an organisation which in that other territory is recognised as a charitable organisation. In such a case the income may be taxed only in the territory of which the individual is a resident.