Where revenue in respect of personal activities exercised by an entertainer or an athlete in his capability as such accrues not to the entertainer or athlete himself however is diverted to another person, that earnings could, notwithstanding the provisions of Articles eight (Business Earnings) and 15 (Independent Personal Companies), be taxed within the Contracting State through which the actions of the entertainer or athlete are exercised.
{An individual who's a resident of a Contracting State instantly earlier than making a visit to the other Contracting State and is quickly present in the different State solely as a business or technical apprentice shall be exempt from tax in that {other Similarly, any debts of a resident of a Contracting State to a resident of the other Contracting State shall, for the aim of determining the taxable capital of the first-mentioned resident, be deductible below the identical Industrial Contracting situations (including rules governing the allowable debt to equity ratio) as if that they had been contracted to a resident of the primary-talked about State.
For functions of this paragraph, earnings from labor or personal companies contains pensions (as defined in paragraph four of Article 21 (Personal Pensions and Annuities)) paid in respect of such companies. Notwithstanding the preceding provisions of this paragraph, remuneration described in Article 22 (Social Security Payments) shall be treated as income from sources inside a Contracting State only if paid by or from the general public funds of that Contracting State or a political subdivision or local authority thereof.
No earnings shall be attributed to a everlasting institution of a resident of one of many Contracting States within the different Contracting State merely by purpose of the purchase of products or merchandise by that permanent institution, or by the resident of which it is a everlasting establishment, for the account of that resident. In such a case the provisions of Article eight (Enterprise Income) or Article 15 (Independent Personal Providers) shall apply.
