A Proposal to Address Key Tax Treaty Issues for Non-Resident Entertainers and Sportspersons
Journal
International; OECD
Bulletin for International Taxation 2025 (Volume 79), No. 11
The sports and entertainment industry is a major economic driver but faces cross-border tax challenges under article 17 of the OECD Model. This article argues that article 17 is unnecessary, yet politically difficult to repeal, and instead proposes targeted amendments and a multilateral approach to address the challenges.