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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 7 and 15 of this Convention, income derived by a resident of a Contracting State as a professional artiste 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 a professional 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 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 what is set forth in paragraphs (1) and (2) of this Article, income derived from the activities mentioned in paragraph (1) of this Article, shall be tax exempt in the Contracting State wherein such activities are performed, if the visit to that State is financed, wholly or substantially, with public or governmental funds from any of the Contracting States.