ARTISTES AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
ARTISTES AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 15 and 16, income derived by a resident of a Contracting Party as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other Contracting Party, may be taxed in that other Party.
ARTISTES AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. Where income in respect of personal activities exercised by an entertainer or a sportsperson in his capacity as such accrues not to the entertainer or sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised. Paragraphs 1 and 2 of this Article shall not apply to income derived by a resident of a Contracting State from activities exercised in the other Contracting State if the visit to that other State is supported wholly or mainly by public funds of the first-mentioned State, a political subdivision or a local authority thereof, or takes place under a cultural agreement between the Governments of the Contracting States. In such case, the income shall be taxable only in the Contracting State of which the entertainer or sportsperson is a resident.
ARTISTES AND SPORTSPERSONS. 241 262 263 Article 18: Pensions and social security payments . . . . . . 269 Article 19: Government service . . . . . . . . . . . . . . . . . . 289 Article 20: Students . . . . . . . . . . . . . . . . . . . . . . . . . 294 Article 21: Other income . . . . . . . . . . . . . . . . . . . . . . 299 COMMENTARY ON CHAPTER IV: TAXATION OF CAPITAL . 305 Article 22: Capital . . . . . . . . . . . . . . . . . . . . . . . . . . 305 COMMENTARY ON CHAPTER V: METHODS FOR THE ELIMINATION OF DOUBLE TAXATION 308 Article 23: Methods for the elimination of double taxation 308 COMMENTARY ON CHAPTER VI: SPECIAL PROVISIONS . . . 339 Article 24: Non-discrimination . . . . . . . . . . . . . . . . . . 339 Article 25: Mutual agreement procedure 366 Page Article 26: Exchange of information . . . . . . . . . . . . . . . 435 Article 27: Assistance in the collection of taxes . . . . . . . . 470 Article 28: Members of diplomatic missions and consular posts 480 COMMENTARY ON CHAPTER VII: FINAL PROVISIONS . . . . 483 Articles 29 and 30: Entry into force and termination . . . . . . 483 Introduction INTRODUCTION
ARTISTES AND SPORTSPERSONS. 01 Notwithstanding the provisions of Articles 14 and 15 of this Convention, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a Sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 02 Where income in respect of personal activities exercised by an entertainer or a Sportsperson in his capacity as such accrues not to the entertainer or Sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15 of this Convention, be taxed in the Contracting State in which the activities of the entertainer or Sportsperson are exercised.
ARTISTES AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of a Contracting State as an entertainer, such as a theater, motion picture, radio or television artiste, or a musician, or a sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. Income derived by an entertainer or a sportsperson who is a resident of a Contracting State from that resident’s personal activities relating to that resident’s reputation as an entertainer or sportsperson exercised in the other Contracting State may be taxed in that other State,
ARTISTES AND SPORTSPERSONS. 82. A number of older tax treaties do not include paragraph 2 of Article 17 (Artistes and sportspersons), which deals with the use of so-called “star- companies”. In order to avoid the possible application of provisions based on paragraph 1 of that Article, residents of countries that have concluded such treaties may be tempted to arrange for the income derived from their activi- ties as artistes or sportspersons, or part thereof, to be paid to a company set up for that purpose.
