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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Ivory Coast: double taxation agreement, Article 18: Artistes and Athletes

(1) Notwithstanding the provisions of Articles 15 and 16, income derived by a residentof a Contracting State as an entertainer, such as a theatre, motion picture, radio ortelevision artiste, or a musician, or as an athlete, from his personal activities as suchexercised 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 anathlete in his capacity as such accrues not to the entertainer or athlete himself but toanother person, that income may, notwithstanding the provisions of Articles 7, 15 and 16,be taxed in the Contracting State in which the activities of the entertainer or athleteare exercised.

(3) The provisions of paragraphs (1) and (2) of this Article shall not apply toprofits, remunerations, wages, salaries and similar income derived from activitiesperformed in a Contracting State by entertainers or athletes if the visit of suchentertainers or athletes to that State is wholly or substantially supported by publicfunds of the other Contracting State.