ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 and 14 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 that person’s 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 entertainer or a sportsperson in that person’s capacity as such accrues not to the entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Articles 7 and 14 of this Convention, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised. 3. The provisions of 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 as envisaged in paragraphs 1 and 2 of this Article, if the visit to that other State is supported wholly or mainly by public funds of the first-mentioned Contracting State, a political subdivision or a local authority thereof, or takes place under a cultural agreement or arrangement between the Governments of the Contracting States. In such a case, the income shall be taxable only in the first-mentioned Contracting State.
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Samples: Double Taxation Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
ENTERTAINERS AND SPORTSPERSONS. (1. ) Notwithstanding the provisions of Articles 7 and 14 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 that person’s 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 entertainer or a sportsperson in that person’s capacity as such accrues not to the entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Articles 7 and 14 of this Convention, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
(3. ) The provisions of paragraphs 1 (1) and 2 (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 as envisaged in paragraphs 1 (1) and 2 (2) of this Article, if the visit to that other State is supported wholly or mainly by public funds of the first-mentioned Contracting State, a political subdivision or a local authority thereof, or takes place under a cultural agreement or arrangement between the Governments of the Contracting States. In such a case, the income shall be taxable only in the first-mentioned Contracting State.
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Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 Article 14 and 14 of this Convention15, 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 that personresident’s 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 entertainer or a sportsperson in that person’s capacity acting as such accrues not to the entertainer or sportsperson but to another an- other person, that income may, notwithstanding the provisions of Articles 7 and 14 of this Convention14, be taxed in the Contracting State in which the activities of the entertainer or sportsperson sports- person are exercised. The provisions of the preceding sentence shall not apply if it is established that neither the entertainer or the sportsperson himself, nor persons related to him, participate directly in the profits of such person.
3. The provisions of paragraphs Paragraphs 1 and 2 of this Article shall not apply to income derived by a resident of a Contracting State from activities exercised performed in the other Contracting a Con- tracting State as envisaged in paragraphs 1 and 2 of this Article, by entertainers or sportspersons if the visit to that other State is supported activities of the entertainer or sportsperson are funded, directly or indirectly, wholly or mainly by from public funds of the first-mentioned other Contracting State, a political subdivision or a local authority thereof, or takes place under a cultural agreement or arrangement between the Governments of the Contracting States. In such a case, the income shall be taxable only in the first-mentioned Contracting StateState of which the enter- tainer or sportsperson is a resident.
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ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 and 14 of this Convention14, 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 that personresident’s personal activities as such exercised in the other Contracting State, State may be taxed in that other State.
2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in that person’s capacity acting as such accrues not to the entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Articles 7 and 14 of this Convention14, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
3. The Notwithstanding the provisions of paragraphs 1 and 2 of this Article, income mentioned in this Article shall not apply accruing to income derived by a an entertainer or sportsperson resident of a Contracting State shall be exempt from activities exercised tax in the other Contracting State as envisaged State, in paragraphs 1 and 2 which the activity of the entertainer or sportsperson is exercised, provided that this Article, if the visit to that other State activity is supported wholly or mainly supported by public funds of the first-mentioned Contracting State, a State or political subdivision subdivisions or a local authority authorities thereof, or takes place under a cultural agreement or arrangement between the Governments of the Contracting States. In such a case, the income shall be taxable only in the first-mentioned Contracting StateState of which the entertainer or sportsperson is a resident.
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ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 7, 14 and 14 of this Convention15, 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 that person’s 's personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting State.
2. Where income in respect of personal activities exercised by an entertainer or a sportsperson in that person’s 's capacity as such accrues not to the entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Articles 7 7, 14 and 14 of this Convention15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
3. The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived by a resident entertainers or sportspersons who are residents of a Contracting State from personal activities as such exercised in the other Contracting State as envisaged in paragraphs 1 and 2 of this Article, if the their visit to that other Contracting State is supported wholly or mainly by supported from the public funds of the first-mentioned Contracting State, a including those of any political subdivision or subdivision, a local authority or statutory body thereof, nor to income derived by a non-profit making organization in respect of such activities provided no part of its income is payable to, or takes place under a cultural agreement is otherwise available for the personal benefit of its proprietors, founders or arrangement between the Governments of the Contracting States. In such a case, the income shall be taxable only in the first-mentioned Contracting Statemembers.
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Samples: Income Tax Agreement
ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 7, 15 and 14 of this Convention16, 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 that person’s 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 entertainer or a sportsperson in that person’s capacity as such accrues not to the entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Articles 7 7, 15 and 14 of this Convention16, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
3. The provisions of paragraphs 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 as envisaged in paragraphs 1 and 2 of this Article2, if the visit to that other State is supported wholly or mainly by public funds of the first-mentioned Contracting State, a political subdivision or a local authority thereof, or takes place under a cultural agreement or arrangement between the Governments of the Contracting States. In such a case, the income shall be taxable only in the first-mentioned Contracting StateState of which the entertainer or sportsperson is a resident.
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