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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 14 and 15, income derived by a resident of a Contracting State from personal activities exercised in the other Contracting State as an entertainer, such as a theater artist, cinema, radio or television or musician or athlete, may be taxed in that other State.

(2) Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State where they engage in activities of the entertainer or athlete.

(3) The provisions of the preceding paragraphs shall not apply to income from activities performed in a Contracting State by entertainers or athletes if the visit to that State is wholly or substantially public expense of the other Contracting State or of one of its political subdivisions or local authorities. In such case, the income shall be taxable only in the Contracting State in which the entertainer or sportsperson is a resident.