Special rules apply for entertainers and sportspeople who perform in the UK but who are not resident for UK tax purposes.

Income from an activity performed in the UK is treated as a separate UK trade (or profession or vocation), unless the individual already has a UK trade, or the activity is part of an employment.

Income tax is paid on the profits from this deemed trade unless relief is available under a double tax treaty. Some treaties do provide for this relief, even though the OECD model treaty states the income can be taxed in the country the activities are exercised in.

Article 17 of the OECD model treaty reads as follows:

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