They used to be called Athletes and Artistes (and still are in several treaties). The OECD now refers to them as entertainers and sportsmen. The OECD recently released a discussion draft to propose some changes to their commentary.

The change that most twigged my interest is the fact that a one-time amateur sports winner of a race could now be considered in this category. So, if the running race has a cash prize – it could be subject to tax withholding.

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