ARTICLE 18
Income Earned by Entertainers and Athletes
1. Notwithstanding the provisions of Articles 15
(Independent Personal Services) and 16 (Dependent Personal
Services), 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 an athlete, from his
personal activities as such exercised in the other Contracting
State, may be taxed in that other state, except where the amount
of the net income derived by such entertainer or athlete from
such activities (after deduction of all expense incurred by him
in connection with his visit and performance) does not exceed
one thousand five hundred United States dollars ($1,500) or its
equivalent in Indian rupees for the taxable year concerned.
2. Where income in respect of activities exercised by an
entertainer or an athlete in his capacity as such accrues not to
the entertainer or athlete but to another person, that income of
that other person may, notwithstanding the provisions of Articles
7 (Business Profits), 15 (Independent Personal Services) and 16
(Dependent Personal Services), be taxed in the Contracting state
in which the activities of the entertainer or athlete are
exercised unless the entertainer, athlete, or other person
establishes that neither the entertainer or athlete nor persons
related thereto participate directly or indirectly in the profits
of that other person in any manner, including the receipt of
deferred remuneration, bonuses, fees, dividends, partnership
distributions, or other distributions.
3. Income referred to in the preceding paragraphs of this
Article derived by a resident of a Contracting state in respect
of activities exercised in the other Contracting state shall not
be taxed in that other state if the visit of the entertainers or
athletes to that other state is supported wholly or substantially
from the public funds of the Government of the first-mentioned
Contracting state, or of a political subdivision or local
authority thereof.
4. The competent authorities of the Contracting States may,
by mutual agreement, increase the dollar amounts referred to in
paragraph 1 to reflect economic or monetary developments.