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HMRC internal manual

Double Taxation Relief Manual

DT: Philippines: double taxation agreement, Article 16 Artistes and Athletes

(1) Notwithstanding the provisions of Articles 13 and 14, income derived by public entertainers, such as theatre, motion picture, radio or television artistes, and musicians and by athletes, from their personal activities as such may be taxed in the Contracting State in which those activities are exercised.

(2) Where income in respect of personal activities as such of an entertainer or athlete accrues not to that entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 13 and 14, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.

(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to income derived from activities performed in a Contracting State by entertainers and athletes ifthe visit to that Contracting State is substantially supported by public funds of the other Contracting State, including those of any political subdivision, local authority orstatutory body thereof, nor to income derived by a non-profit making organisation inrespect of such activities provided no part of its income is payable to, or is otherwise available for the personal benefit of its proprietors, members or shareholders and the organisation is certified as qualifying under this provision by the competent authority ofthe other State.