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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 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 athlete in his personal 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) The provisions of paragraphs (1) and (2) shall not apply to income derived by artistes or athletes who are residents of a Contracting State in respect of the exercise of their activities in the other Contracting State, provided that their visit to the other Contracting State was substantially financed from public funds of the first-mentioned Contracting State or one of its political subdivisions or local authorities. Further, the provisions of paragraph (1) and (2) of this Article shall not apply to income derived from public service organizations for such activities of artistes or athletes, but only if such income was not paid by or available for the personal benefit of their owners, constructors or members.