The 1992 amendments to the OECD Commentary on Article 17 of the OECD Model Convention have effectuated that it is nowadays a widely accepted concept that source countries tax income of foreigners from artistic/athletic performance in the hands of an interposed company. Daniel Felderer analyzes the scope of Article 17 paragraph 2 of the OECD MC and concludes that source taxation of the entire performance fee received by the interposed company is not in accordance with the notion of income from personal performance as an artiste/sportsman as defined in Article 17. He further concludes that in non-abusive structures income of foreigners from artistic/athletic performance may only be taxed in the hands of the performing artistes/sportsmen themselves but not in the hands of the interposed company. A more detailed analysis of Art. 17 para. 2 in English will soon be published in W. Loukota/Stefaner (eds.), Taxation of Artistes and Sportsmen in International Tax Law (2007).