ENTERTAINERS 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 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. 2. Where income in respect of personal activities exercised by an entertainer or a sportsperson is 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 and 14, 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 shall not apply to income derived by entertainers or sportspersons who are residents of a Contracting State from their personal activities as entertainers or sportspersons exercised in the other Contracting State if their visit to that other State is supported wholly or mainly by public funds of the first-mentioned Contracting State, 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 Contracting State of which the entertainer or sportsperson, as the case may be, is a resident.
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Samples: Double Taxation Agreement, Double Taxation Agreement, Botswana Ireland Double Taxation Avoidance Agreement
ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 14 and 1415, 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 sportspersonsportsman, from his 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 is sportsman in his capacity as such accrues not to the entertainer or sportsperson sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7 7, 14 and 1415, be taxed in the Contracting State in which the activities of the entertainer or sportsperson sportsman are exercised.
3. The Notwithstanding the preceding provisions of paragraphs 1 and 2 shall not apply to this Article, income derived by entertainers or sportspersons who are residents of a Contracting State from their personal the activities as entertainers or sportspersons exercised in the other Contracting State if their visit to shall be exempt from tax in that other Contracting State is if such activities are supported wholly or mainly by from public funds of the first-mentioned Govemment of either Contracting State, a political subdivision or a local authority thereof, or takes take place under a plan of cultural agreement or arrangement exchange between the Governments of the Contracting States. In such a case, the income shall be taxable only in the Contracting State of which the entertainer or sportsperson, as the case may be, is a resident.
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Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 and 1415, 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 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 is his in that person’s capacity as such accrues not to the entertainer or sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 1415, 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 shall not apply to income derived by entertainers or sportspersons who are residents a resident of a Contracting State from their personal activities as entertainers or sportspersons exercised in the other Contracting State as envisaged in paragraphs 1 and 2, if their 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 of which the entertainer or sportsperson, as the case may be, is a residentState.
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Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation
ENTERTAINERS 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 theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his that resident’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 is his capacity acting as such accrues not to the entertainer or sportsperson himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 14, 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 shall not apply to income derived from activities performed in a Contracting State by entertainers or sportspersons who are residents of a Contracting State from their personal activities as entertainers or sportspersons exercised in if the other Contracting State if their visit to that other State is supported wholly or mainly supported by public funds of one or both of the first-mentioned Contracting StateStates or political subdivisions, local authorities or a local authority statutory bodies thereof, or takes place under the activities are approved by both Contracting States within an agreed framework of a cultural agreement or arrangement sports exchange program between the Governments of the Contracting States. In such a case, the income shall be is taxable only in the Contracting State of in which the entertainer or sportsperson, as the case may be, sportsperson is a resident.
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Samples: Double Taxation Agreement, Double Taxation Agreement
ENTERTAINERS AND SPORTSPERSONS. 1. Notwithstanding the provisions of Articles 7 14 and 1415, 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.
2. Where income in respect of personal activities exercised by an entertainer or a sportsperson is 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 7, 14 and 1415, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised, unless it is established that neither the entertainer or sportsperson nor persons related thereto (whether or not residents of that State) participate directly or indirectly in the receipts or profits of that other person in any manner, including the receipt of deferred remuneration, bonuses, fees, dividends, partnership distributions, or other distributions.
3. The provisions of paragraphs 1 and 2 shall not apply to income derived by entertainers or sportspersons who are residents a resident of a Contracting State from their personal activities as entertainers or sportspersons exercised in the other Contracting State State, if their the visit to that other State is supported wholly or mainly supported by public funds of one or both of the first-mentioned Contracting State, States or a political subdivisions or 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 Contracting State of which the entertainer or sportsperson, as the case may be, sportsperson is a resident.
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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 14 and 1415, 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.
2. Where income in respect of personal activities exercised by an entertainer or a sportsperson is 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 7, 14 and 1415, 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 shall not apply to income derived by entertainers or sportspersons who are residents a resident of a Contracting State as an entertainer or a sportsperson from their personal activities as entertainers or sportspersons exercised in the other Contracting State State, if their the visit to that other State is supported wholly or mainly by public funds of one or both of the first-mentioned Contracting State, States or a political subdivisions or local authority authorities or statutory body 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 Contracting State of which the entertainer or sportsperson, as the case may be, sportsperson is a resident.
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