Aircraft Pilots and Drone Operators under Tax Treaties: Air Show Performances, Technical Services and the Limits of Article 17
New
Journal
International; OECD
Bulletin for International Taxation 2026 (Volume 80), No. 3
This article examines the treaty classification of income earned by aircraft pilots and drone operators in air show performances. It distinguishes between competitive air-sport events, non-competitive demonstration displays and record-style stunt performances, and argues that article 17 applies only in cases in which pilots or drone operators participate in formal rule-based sporting competitions.