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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.

ARTICLE 18

Artists and Athletes

(1) Notwithstanding the provisions of Articles 15 and 16, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artist, or a musician, or as an athlete, from his or her 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 artist or an athlete in his capacity as such accrues not to the artist or athlete him or herself but to another person, that income may, notwithstanding the provisions of Articles 7, 15, and 16, be taxed in the Contracting State in which the activities of the artist or athlete are exercised.

(3) Notwithstanding the provisions of paragraphs (1) and (2), income derived by a resident of a Contracting State from the activities referred to in paragraph (1) in the scope of cultural exchange between the two Contracting States is exempt from tax in the Contracting State in which the activities are exercised if the visit to that State is wholly or largely funded by one of the Contracting States or both of the Contracting States, their political or administrative subdivisions, local authorities or public institutions.