Entertainers and Sportspersons (Article 16) - Text Fragment
令和7年11月21日|p.23
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1.Notwithstanding the provisions of Article 14, income derived by a resident of a
employment shall be taxable only in that Contracting State unless the employment is
Contracting State as an entertainer, such as a theatre, motion picture, radio or television
exercised in the other Contracting State. If the employment is so exercised, such
artiste, or a musician, or as a sportsperson, from that resident's personal activities as such
remuneration as is derived therefrom may be taxed in that other Contracting State.
exercised in the other Contracting State, may be taxed in that other Contracting State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a
2. Where income in respect of personal activities exercised by an entertainer or a
resident of a Contracting State in respect of an employment exercised in the other
sportsperson acting as such accrues not to the entertainer or sportsperson but to another
Contracting State shall be taxable only in the first-mentioned Contracting State if.....r in tthhee
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.
(a) the recipient is present in the other Contracting State for a period or periods
not exceeding in the aggregate 183 days in any twelve month period