ARTICLE 18

Public Entertainers

This Article provides that, notwithstanding Articles 16 (Independent Personal Services) and 17 (Dependent Personal Services), income derived by an individual resident in one Contracting State from his performance of personal services in the other Contracting State as a public entertainer, such as a theater, motion picture, radio or television artist, a musician, or an

athlete may be taxed by the other Contracting State only if the gross amount of such income exceeds $400 or its equivalent in Israeli pounds for each day the individual is present in the other Contracting State for the purpose of performing such services therein. If the entertainer’s gross income exceeds $400 per day, he may be taxed on the full amount of his income, not just the amount in excess of $400.

If the individual receives a fixed amount for performing the services on more than one day, the amount received will be pro-rated over the number of days the individual performs the services. Thus, for example, if am entertainer resident in Israel receives $5,000 to perform in a series of 5 concerts in the United States on 5 different days and spends an additional 5 days in the United States in rehearsal for those concerts over a two week period, he will be considered to have received $500 for each day and thus, pursuant to this Article, he may be taxed by the United States.

Income derived from services rendered by producers, directors, technicians, and others who are not public entertainers is taxable in accordance with the provisions of Article 16 (Independent Personal Services), or Article 17 (Dependent Personal Services), as the case may be.

Under the saving clause of paragraph (3) of Article 1 (General Rules of Taxation), if the individual is a citizen of a Contracting State, that State may tax his income without regard to this Article.