Australian Tax Treaties
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
Notwithstanding the provisions of Articles 14 and 15, income derived by entertainers (such as theatrical, motion picture, radio or television artistes and musicians) or sportspersons from their personal activities as such may be taxed in the Contracting State in which these activities are exercised.
2.
Where income in respect of the personal activities of an entertainer or sportsperson 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 those activities are exercised.
3.
Notwithstanding the provisions of paragraph 1, income derived from activities referred to in paragraph 1 and performed within the framework of a cultural exchange agreed between Governments of the Contracting States shall be exempt from tax in the Contracting State in which these activities are exercised.
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