エンターテイナーおよびスポーツ選手（第16条）
令和7年10月31日|p.29
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ARTICLE 16
ENTERTAINERS AND SPORTSPERSONS
1. Notwithstanding the provisions of Article 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 resident's personal activities as such
exercised in the other Contracting State, may be taxed in that other Contracting State.
2. Where income in respect of personal activities exercised by an entertainer or a
sportsperson acting as such accrues not to the entertainer or sportsperson but to another
person, that income may, notwithstanding the provisions of Article 14, be taxed in the
Contracting State in which the activities of the entertainer or sportsperson are exercised.