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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 of this Convention, income derived by a resident of a Contracting State such as an entertainer or musician, theater, cinema, radio or television artiste, or as an athlete, from his 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 himself but to another person, that income notwithstanding the provisions of Articles 7, 14 and 15 of this Convention, may be taxed in the Contracting State in which the activities of the artiste or athlete are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2) of this Article, the income derived from the activity mentioned in paragraph (1) of this Article within the framework of a cultural or sports exchange program approved and financed totally or in part by the governments of both the Contracting States and which are not carried out with an aim to make profits, are exempted from taxes in the Contracting State where these activities are carried out.