Article 17 of the OECD Model overrides the business profits article (art. 7; see ¶171-100) and the employment article (art. 15; see Schwarz on Tax Treaties ¶17-650) in the case of entertainers and sportspersons. The income from the exercise of their personal activities as such may be taxed in the state in which those activities are exercised (the ‘host state’). The right of the host state to tax the income is also given where the income accrues to person other than the entertainer/sportsperson.

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