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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Austria: Entertainer and sportsmen

The protocol (SI1994/768) mentioned at DT2750 provides that income derived by a resident of Austria from entertainment or sporting activities performed in the United Kingdom under a cultural agreement between the United Kingdom and Austria, or derived by a non-profit making organisation, or by an entertainer or athlete who provides services to such an organisation, is to be exempt from tax in the United Kingdom.

A similar exemption applies in relation to United Kingdom residents performing activities in Austria under such cultural agreements, etc.

Although the reference in Article 17 is to an “athlete” rather than the more usual “sportsman”, the Article covers all sportsmen (and sportswomen) and not merely those involved in track and field athletics.