Artist taxation has been an issue since the source taxation option for artistes and sportsmen was introduced in Article 17 of the OECD model tax convention in the sixties. Because of the tax avoidance of top stars, states introduced a source withholding tax when non-resident artists were performing on their territory.

This was different from the normal taxing rules for self-employed, who need a fixed place of business to be taxable in the state of work, and for employees, who can go with their employer to the state of work and remain taxable in the residence state. This stricter rule for performing artists very often leads to double taxation, because they are not able to obtain a foreign tax credit in their residence state. The OECD has decided in 2014 to keep this special taxing rule, because its Member States are afraid that otherwise top stars can evade taxation.


Within the EU, the cross-border artist taxation is an obstacle to performing in other Member States. Touring artists subject to artist taxation include: musicians, singers, conductors, actors, dancers, circus artists, and any other performer on stage. In other words those working off stage, such as the technical crew and those in the administration are (in principle) not affected. Together with the individual artists, the enterprises (including the touring companies as well as the local organisers) are also subject to the issue of double taxation.

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