Replaced by new DTA, which applies in UK from 1st April 2003 for
CT, 6th April 2003 for IT and 1st January 2004 for PRT. For US
withholding taxes it applies from 1st May 2003 and for other US
taxes from 1st January 2004. See DT19939F.
(1) Notwithstanding the provisions of Articles 14
(Independent personal services) and 15 (Dependent personal
services) income derived by 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 these activities are exercised,
except where the amount of the gross receipts derived by an
entertainer or athlete, including expenses reimbursed to him or
borne on his behalf, from such activities do not exceed 15,000
United States dollars or its equivalent in pounds sterling in the
tax year concerned.
(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 (Business profits), 14
(Independent personal services), and 15 (Dependent personal
services), be taxed in the Contracting State in which the
activities of the entertainer or athlete are exercised. For the
purposes of the preceding sentence, income of an entertainer or
athlete shall be deemed not to accrue to another person if it is
established that neither the entertainer or athlete, nor persons
related thereto, participate directly or indirectly in the profits
of such other person in any manner, including the receipt of
deferred remuneration, bonuses, fees, dividends, partnership
distributions or other distributions.
