Article 17 Entertainers and sportpersons

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.

The provisions of paragraphs 1 and 2 shall not apply to income derived by a resident of a Contracting State from activities performed in the other Contracting State by entertainers or sportspersons if the visit to that State is substantially supported by public funds of the other Contracting State or a political subdivision or local authority thereof, or takes place under a cultural agreement 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 is a resident.