Taxation of Entertainers and Sportspersons Performing Abroad

“Taxation of Entertainers and Sportspersons Performing Abroad” comprises the proceedings and working documents of an annual seminar organized by the Università Cattolica del Sacro Cuore and held in Milan in November 2015. This is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in artistic and sport activities. It begins with a comparative analysis of the domestic tax regimes of such individuals. It then examines the impact on such regimes of EU law, with a particular emphasis on the case law of the Court of Justice of the European Union. Finally the book addresses selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) the recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) the most relevant tax treaty issues concerning the qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising under the current OECDModel Tax Convention.