Taxation of Artistes and Sportsmen in International Tax Law

S. 55The Historical Background of Art. 17 OECD Model

Yasmin Wagner

S. 57I. Introduction

In the first half of the twentieth century the business of entertainers grew kept pace with the growing possibilities to cover large distances in a minimum of time. “Stars” were born and attracted public interest more than ever before. The media spread their fame all over the world. Huge rewards, which were formerly unheard of, were paid to such stars and countries started to think about how they could receive a piece of this cake.

In 1959 the OEEC introduced a special provision dealing with the allocation of taxation rights on income derived from entertainment and athletic activities. Since then, this provision as well as the Commentary thereto has been subject to minor and major changes. Therefore, not only the legal problems arising from the application of the article itself but also its historical development is of great interest. This article gives an overview of the historical development of the entertainers and sportsmen clause starting with starting with material from the period before the clause was introduced]

The reasons for the implementation of the provisi...