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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 Sportsmen

(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 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.