Taxation of Artistes and Sportsmen in International Tax Law
1. Aufl. 2007
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S. 35Notion of Sportsmen in Art. 17 OECD Model
Jiří Zoubek
S. 37I. Introduction
Article 17 of the OECD Model prescribes a general rule with respect to the taxation of income from entertainment, artistic and sporting activities. A distributive rule concerning this type of income is set forth in this article of the OECD Model, where it is stipulated that the right of taxation for income derived by artistes and sportsmen be distributed between both Contracting States. Accordingly, income which falls within the scope of Article 17 may be taxed in the State of source, i.e., the allocation of the right of taxation is driven by the method for elimination of double taxation employed in Article 23.
For a comprehensive view of this matter and for the purposes of the explanation which follows, it should be noted that the current wording of the title and paragraph 1 of Article 17 of the OECD Model read as follows:
“ARTISTES AND SPORTSMEN
Notwithstanding the provisions of Articles 7 and 15, 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 sportsman, from...