Loukota/Stefaner

Taxation of Artistes and Sportsmen in International Tax Law

1. Aufl. 2007

ISBN: 978-3-7073-1205-8

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Taxation of Artistes and Sportsmen in International Tax Law (1. Auflage)

S. 207Taxation of Contract Splitting with Artistes and Sportsmen according to the OECD Model

Tobias Wehrli

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I.	Introduction
	1.1	Relationship of Article 17 to other allocation rules of the OECD Model
	1.2	Relationship of Article 17 to Article 7 OECD Model
	1.3	Relationship of Article 17 to Article 12 OECD Model

II.	Contractual relationships with performing artiste
	2.1	Separation of performance and production
		2.1.1	Supply of production through third parties
		2.1.2	Supply of transportation and accommodation through organiser
		2.1.3	Artiste acting as an agent
	2.2	Artiste concludes contracts with the production company

III.	Taxation of contract splitting
	3.1	Separation of performance and production
		3.1.1	Supply of production through third parties
		3.1.2	Supply of transportation and accommodation through organiser
		3.1.3	Artiste acting as an agent
	3.2	Artiste concludes contracts with the production company

IV.	ConclusionS. 208

S. 209I. Introduction

This thesis is focusing on the question of the extent to which contractual relationships may influence the characterization of income and thus the taxation of artistes and sportsmen who perform internationally.

Imagine the case where a world-famous US pop star decides to go on tour in Europe. He plans to have concerts in different cities across Europe. A German concert promoter is interested in engaging the pop star for a live performance. He gets in touch with the artiste’s agent and concludes a contract with him about his artistic performance as such. In addition, the concert promoter signs several other contracts in his own name with production companies about the whole production in connection with the appearance of the artiste, i.e. about lighting and sound, production personnel, support and transport of the artiste as well as the crew, equipment, hotel accommodation, plane tickets, etc. On the other hand, a different contractual relationship could be chosen: instead of providing the whole...

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Taxation of Artistes and Sportsmen in International Tax Law

S. 207Taxation of Contract Splitting with Artistes and Sportsmen according to the OECD Model

S. 209I. Introduction

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