Taxation of Entertainers and Athletes (3)
Sandler, Daniel, F 13/14, F 14/15
Entertainers and athletes are among the most mobile individuals in the world. The nature of the income they earn is varied and, in some cases, substantial. The OECD Model Convention on Income and Capital has had a special provision dealing with entertainers and athletes since the original 1963 draft convention. These lectures introduce issues involved in the taxation of international entertainers and athletes. With the help of case studies, these lectures examine the characterization (for domestic law and tax treaty purposes) of income that entertainers and athletes earn, alternative regimes that can be used by countries to tax such income, the application of EU law to the taxation of such income, and the application of OECD Model provisions (and variations found in bilateral tax treaties).