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WU Vienna Tax law


Karolina Tetlak

Dr. Karolina Tetłak, LL.M. is an assistant professor in tax law at Warsaw University, Poland. She is an expert in sports fiscal law, the taxation of athletes and tax treatment of sports events. An LL.M. graduate of Harvard Law School, she is recognized as the top global expert on international sports taxation and one of the leading young academics in Poland. She has been awarded numerous prizes, research grants and scholarships, including the European Academic Tax Thesis Award and Joao Havelange Research Grant awarded by FIFA. Fluent in five European languages, she teaches international tax law at numerous universities worldwide and has authored and co-authored many works on tax law. Her PhD thesis on the taxation of international sportspersons has been published in the IBFD’s prestigious Doctoral Series. She has broad practical expertise on income tax, international taxation, VAT and tax procedure. She advises private clients and tax administration, serves as a government expert and has been involved in tax-related arbitration proceedings before the Court of Arbitration for Sport (CAS) and International Centre for Settlement of Investment Disputes (ICSID) under bilateral investment treaties. A member of the International Fiscal Association (IFA), founding member of the International Taxation of Entertainers Group (ITEG).

The OECD Model Tax Convention devotes a separate Article 17 to income derived from the activities of entertainers and sportspersons. Article 17 assigns the primary taxing right in relation to income derived by artistes and athletes to the state of performance, regardless of whether the income is of a business or employment nature. The purpose of this lecture is to discuss the tax treatment of artistic and sports performances under Article 17. In particular, the lecture will explain the reason behind the introduction of this exceptional rule, the scope of income that falls within this provision, income attribution rules, the allocation of taxing rights in relation to income from artistic and sporting activities as well as its anti-avoidance purpose. Examples and case studies will offer an insight into advanced problems arising in connection with the application of double tax treaties to internationally performing artistes and athletes.

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