The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.

The tax rules for international performing artistes are very different from normal tax rules. For instance, taxation occurs in the country of performance, regardless of whether an artiste is self-employed or an employee. Since 1963 the OECD has adopted this special rule in Article 17 of its Model Convention as an anti-avoidance measure, and most countries have taken it over into their tax treaties and national rules. This book provides a clear outline of the relevant rules and considerations.

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This book shows that options are available to improve the taxation of international performing artistes. Some options can be implemented at short notice, but the position could also be drastically amended by completely removing the obstacles for international performing artistes without affecting countries' tax revenue.

• Introduction, aim of the thesis and research methods
• History of non-resident artiste taxation
• Who is an artiste?
• What is performance income?
• Tax treaties: allocation with Article 17
• Elimination of double taxation
• Unequal treatment in the European Community

Dr Dick Molenaar is a partner with All Arts Tax Advisers in Rotterdam, the Netherlands. He specializes in international tax issues of performing artistes. The obstacles resulting from the special tax rules led him to undertake this doctoral research at the Erasmus University of Rotterdam. Dr Molenaar is a member of numerous international organizations and has published books and articles on the international taxation of artistes. He is also on the board of several cultural organizations and participates in various international events.

The mission of the International Bureau of Fiscal Documentation is: “[T]o maintain a knowledge centre providing information about and explanations of international taxation and promoting the study of taxation in general” (Art. 2 of the articles of association). True to this mission, and aware that access to doctoral theses is often limited, IBFD has taken the initiative to make available to a wider public a series of books based on doctoral research, meeting the highest academic standards.

Only contributions that enhance the international academic tax debate are accepted. In order to ensure high quality, every thesis published in this series has been reviewed by academic members of the Board of Trustees, senior IBFD research staff or prominent tax academics worldwide. The series aims to cover all aspects of comparative and international taxation, not only in respect of income tax, but also in respect of VAT and of inheritance, estate and gift taxes.