Australian Tax Treaties
Swiss Convention
CONVENTION BETWEEN AUSTRALIA AND THE SWISS CONFEDERATION FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME, WITH PROTOCOL
CHAPTER III
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TAXATION OF INCOME
ARTICLE 17
Entertainers and sportspersons
1
Notwithstanding the provisions of Articles 14 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 sportsperson, from that person ' s personal activities as such exercised in the other Contracting State, may be taxed in that other State.
2
Where income in respect of personal activities exercised by an entertainer or a sportsperson in that person ' s capacity as such accrues not to that person but to another person, that income may, notwithstanding the provisions of Articles 7 , 14 and 15 , be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised. The provisions of the preceding sentence shall not apply if it is established that neither the entertainer or the sportsperson, nor persons related to the entertainer or the sportsperson, participate directly or indirectly in the profits of such person.
3
Paragraphs 1 and 2 shall not apply to income from activities performed in a Contracting State by entertainers or sportspersons if such income is derived, directly or indirectly, wholly or mainly from public funds of the other Contracting State, a political subdivision or a local authority thereof. In such a case, the income shall be taxable only in the Contracting State of which the entertainer or sportsperson is a resident.
Notwithstanding the provisions of Articles 14 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 sportsperson, from that person ' s personal activities as such exercised in the other Contracting State, may be taxed in that other State.
2
Where income in respect of personal activities exercised by an entertainer or a sportsperson in that person ' s capacity as such accrues not to that person but to another person, that income may, notwithstanding the provisions of Articles 7 , 14 and 15 , be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised. The provisions of the preceding sentence shall not apply if it is established that neither the entertainer or the sportsperson, nor persons related to the entertainer or the sportsperson, participate directly or indirectly in the profits of such person.
3
Paragraphs 1 and 2 shall not apply to income from activities performed in a Contracting State by entertainers or sportspersons if such income is derived, directly or indirectly, wholly or mainly from public funds of the other Contracting State, a political subdivision or a local authority thereof. In such a case, the income shall be taxable only in the Contracting State of which the entertainer or sportsperson is a resident.
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