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. 71The Notion of “Income” in the Sense of Art. 17 OECD Model

Thomas Bramo

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S. 73I. Introduction

Entertainers and athletes are very mobile and their income is often earned in many countries and not only in their country of residence. Therefore, international performing entertainers and athletes are frequently subjected to a special tax treatment.

As soon as an entertainer or athlete becomes well known, his income may be derived from many countries and the ties to the residence country will decrease. From that time onwards, the taxation of these taxpayers becomes more and more difficult. The artist or sportsman begins to spend the greater part of time in various countries abroad and taxation can become particularly problematic given the short stay in and the lack of any strong economic ties with these countries.

Furthermore, entertainers and athletes generate income not only through their personal activities but in many cases their income results from other sources, such as product endorsement, commercials, television appearances etc. and could be even higher than income from the personal performance itself. However, a country’s ability...

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I.	Introduction

II.	The term “income” under the domestic law
	2.1	Basic concept of income tax systems
	2.2	Ability-to-pay principle
	2.3	Problems of economic double taxation
	2.4	Determination of deductibility items

III.	The relation between Tax Treaties and Domestic Law
	3.1	The context clause of Article 3 para. 2 OECD Model
	3.2	The term “income” as used in Article 6 OECD Model
	3.3	The term “profits” as used in Article 7 OECD Model
	3.4	The term “remuneration” as used in Article 15 OECD Model
	3.5	Conclusion

IV.	Income within the meaning of Article 17 OECD Model
	4.1	Article 17 para. 1 OECD Model
	4.2	Article 17 para. 2 OECD Model

V.	ConclusionS. 72

Taxation of Artistes and Sportsmen in International Tax Law

S. 71The Notion of “Income” in the Sense of Art. 17 OECD Model

S. 73I. Introduction

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