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HMRC internal manual

International Manual

Description of double taxation agreements: Artistes/entertainers/athletes

This Article is generally entitled artistes and athletes, but the terms entertainers and sportsmen can also be used. We do not consider there is any difference between the terms artistes and entertainers and sportsmen and athletes.

Where an entertainer or athlete (a term which encompasses sports persons in general) who is a resident of one country performs in the other country, that other country is given primary taxing rights over the income he derives from such performance.

If the income from the performance goes not to the entertainer or athlete but to another person, for example a service company, the income can nevertheless be taxed in the country in which the entertainer or athlete performs if that country can do so under its own domestic law.

See INTM168063 for guidance concerning credit relief available to United Kingdom resident entertainers.

Some agreements expressly exclude from these provisions income derived from performances if such activities are performed under cultural arrangements between the two countries or for a non-profit making organisation.