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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 Athlete

(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 or her 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 athlete himself but to another person, that income, notwithstanding the provisions of Articles 7, 14, and 15, may be taxed in the Contracting State in which the activities of the artiste or athlete are exercised.

(3) The provisions of paragraph (1) and (2) of this Article shall not apply if the activities exercised by the artiste or athlete in a Contracting State are entirely or for a substantial part financed by using the public funds of the other Contracting State, one of its political subdivisions or local or territorial authorities.