(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 that person’s personal activities as such
exercised in the other Contracting State‚ may be taxed in that other State.
(2) Notwithstanding the provisions of Article 12‚ income derived by the persons
mentioned in paragraph 1 from their personal activities exercised in the other Contracting
State shall also include remuneration of any kind paid for the use of‚ or the right to use‚
the name‚ the picture or other personal rights of such persons as well as any consideration
for the recording and transmission of the activities mentioned in paragraph 1 by radio or
television.
(3) Where income mentioned in paragraphs 1 and 2 accrues not to the entertainer or
sportsperson 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.
(4) Paragraphs 1 and 3 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 Land‚ 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 case‚ the
income shall be taxable only in the Contracting State of which the entertainer or
sportsperson is a resident.