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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.


Income of Entertainers and Athletes

(1) Notwithstanding the provisions of articles 14 and 15 of this Convention, income derived by a person with permanent residency in a Contracting State as an entertainer-such as a theater, motion picture, radio or television performing artist, or a musician-or as an athlete, from his personal activity exercised in the other Contracting State, may be taxed in that other State.

(2) Where income in respect of personal activity exercised by an entertainer or an athlete 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, 14 and 15 of this Convention, be taxed in the Contracting State in which such activity is performed.