Application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention
The Committee on Fiscal Affairs has examined the application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention and has published a public discussion draft which includes proposals for additions and changes to the Commentary on the OECD Model Tax Convention.
Under Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention, the State in which the activities of a non-resident entertainer or sportsman are performed is allowed to tax the income derived from these activities. This regime differs from that applicable to the income derived from other types of activities making it necessary to determine questions such as what is an entertainer or sportsman, what are the personal activities of an entertainer or sportsman as such and what are the source and allocation rules for activities performed in various countries.
The public discussion document along with submissions on the topic is available at http://www.oecd.org/document/32/0,3343,en_2649_33747_45056800_1_1_1_1,00.html