Domestic Attribution of Income and Taxation of International Entertainers and Sportspersons

This book provides an in-depth analysis of the interplay between domestic income attribution and the proper application of article 17(1) and 17(2) of the OECD Model Convention.

Why This Book?

The attribution of income to a certain taxpayer is an issue that virtually every tax jurisdiction has to deal with, but there is no uniform international consensus on how taxable profits are to be allocated to taxpayers, and the details on how to allocate profits are regulated individually by each state. However, consistent principles for the attribution of income are particularly of interest with regard to the application of article 17 of the OECD Model Convention, the relevant allocation rule for the income of entertainers and sportspersons. This provision applies not only to income that is directly attributable to a given entertainer or sportsperson but also to income from an entertaining or sporting activity that accrues to another person.
 

This book provides detailed insight into the treatment of entertainers and sportspersons in international tax law, with the relevance of the domestic attribution of income for the application of tax treaties with regard to entertainers and sportspersons as the focus of attention. Given this focus, the book also establishes how allocation conflicts – i.e. situations where different states attribute the same item of income to different taxpayers according to their domestic attribution principles – can be resolved in a methodically consistent and comprehensive manner with regard to international entertainers and sportspersons.