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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 as an entertainer such as a musician or a theatre, motion picture, radio or television artiste, or as an athlete, from his personal activities exercised as such 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 to the athlete himself 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 the athlete are exercised.

(3) Notwithstanding the provisions of paragraph (1) and (2) of this Article, income derived by an artiste or athlete from his personal activities exercised in the other Contracting State that are within the scope of an agreement of cultural exchange program between the Contracting States, its political subdivisions or local authorities shall be exempt from taxation in the Contracting State if such activities are mainly financed out of public funds of either one or both of the Contracting States or by its political subdivision or its local authorities.