Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 6
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34is wholly or mainly supported by public funds of
Income for services performed by a resident
United States is substantially supported by pub
Estonia, its political subdivisions, or local au
of France as an employee and member of the
lic funds of Germany, its political subdivisions,
thorities.
regular complement of a ship or an aircraft op
or local authorities.
erated in international traffic is exempt from tax
in the United States.
Finland
Greece
These exemptions do not apply to public en
Income that residents of Finland receive for per
Income that residents of Greece receive for la
tertainers (such as theater, motion picture, ra
forming personal services as independent con
bor or personal services (including practicing
dio, or television artists, or musicians), or
tractors or selfemployed individuals (independ
liberal and artistic professions) is exempt from
sportsmen from France who earn more than
ent personal services) in the United States is
U.S. income tax if they are in the United States
$10,000 in gross receipts, including reimbursed
exempt from U.S. income tax if they do not
for no more than 183 days during the tax year
expenses, from their entertainment activities in
have a fixed base regularly available to them in
and the pay is not more than $10,000. The pay,
the United States during the tax year. Regard
the United States for performing the services. If
regardless of amount, is exempt from U.S. in
less of these limits, income of French entertain
they have a fixed base available in the United
come tax if it is for labor or personal services
ers or sportsmen is exempt from U.S. tax if their
States, they are taxed on the income attributa
performed as employees of, or under contract
visit is principally supported by public funds of
ble to the fixed base.
with, a resident of Greece or a Greek corpora
France.
tion or other entity of Greece, and if the resi
Income that residents of Finland receive for
dents are in the United States for no more than
These exemptions do not apply to directors'
labor or personal services performed in the Uni
183 days during the tax year.
fees and similar payments received by a resi
ted States as employees (dependent personal
dent of France as a member of the board of di
services) is exempt from U.S. income tax if the
Hungary
rectors of a company that is a resident of the
residents meet three requirements.
United States.
They are in the United States for no more
Income that residents of Hungary receive for
than 183 days during any 12month period.
performing personal services as independent
Germany
Their income is paid by, or on behalf of, an
contractors or selfemployed individuals (inde
employer who is not a resident of the Uni
pendent personal services) in the United States
ted States.
Income that residents of Germany receive for
during the tax year is exempt from U.S. tax if the
Their income is not borne by a permanent
personal services as independent contractors
residents:
establishment, fixed base, or trade or busi
or selfemployed individuals are subject to the
Are in the United States for no more than
ness that the employer has in the United
provisions of Article 7 (Business Profits) of the
183 days during the tax year, and
States.
treaty. Under that provision, business profits are
Do not have a fixed base regularly availa
exempt from U.S. income tax unless the individ
ble in the United States.
The exemption does not apply to pay re
ual has a permanent establishment in the Uni
If they have a fixed base available in the United
ceived by a resident of Finland who is an em
ted States. If they have a permanent establish
States, they are taxed on the income attributa
ployee and member of the regular complement
ment in the United States, they are taxed on the
ble to the fixed base.
of a ship or aircraft operated in international traf
profit attributable to the permanent establish
fic by a resident of the United States.
ment.
Income that residents of Hungary receive for
labor or personal services performed in the Uni
These exemptions do not apply to income
Income that residents of Germany receive
ted States as employees (dependent personal
residents of Finland receive as public entertain
for labor or personal services performed in the
services) is exempt from U.S. income tax if the
ers or sportsmen if the gross income, including
United States as employees (dependent per
residents meet three requirements.
reimbursed expenses, is more than $20,000 for
sonal services) is exempt from U.S. tax if the
They are in the United States for no more
their personal activities in the United States dur
residents meet three requirements.
than 183 days during the tax year.
ing the calendar year.
They are in the United States for no more
Their income is paid by or on behalf of an
than 183 days during the calendar year.
employer who is not a resident of the Uni
France
The income is paid by, or on behalf of, an
ted States.
employer who is not a resident of the Uni
Their income is not borne by a permanent
ted States.
Income that residents of France receive for per
establishment or a fixed base that the em
The income is not borne by a permanent
forming personal services as independent con
ployer has in the United States.
establishment that the employer has in the
tractors or selfemployed individuals (independ
United States.
ent personal services) in the United States is
Pay received by an employee who is a
exempt from U.S. income tax if they do not
member of the regular complement of a ship or
Pay received by a resident of Germany for
have a fixed base regularly available to them in
aircraft operated by a Hungarian enterprise in
services performed as an employee and mem
the United States for performing the services. If
international traffic is exempt from U.S. tax. If
ber of the regular complement of a ship or air
they have a fixed base available in the United
the ship or aircraft is operated by a U.S. enter
craft operated in international traffic is exempt
States, they are taxed on the income attributa
prise, the pay is subject to U.S. tax.
from U.S. tax.
ble to the fixed base.
Iceland
The exemption does not apply to directors'
Income that residents of France receive for
fees and other similar payments received by a
labor or personal services performed in the Uni
resident of Germany for services performed in
Income that residents of Iceland receive for per
ted States as employees (dependent personal
the United States as a member of the board of
sonal services as independent contractors or
services) is exempt from U.S. income tax if the
directors of a company resident in the United
selfemployed individuals is subject to the provi
residents meet three requirements.
States.
sions of Article 7 (Business Profits) of the treaty.
They are in the United States for no more
Under that provision, business profits are ex
than 183 days in any 12month period.
Income residents of Germany receive as
empt from U.S. income tax unless the individual
Their income is paid by, or on behalf of, an
public entertainers (such as theater, motion pic
has a permanent establishment in the United
employer who is not a resident of the Uni
ture, radio, or television artists, or musicians) or
States. If they have a permanent establishment
ted States.
athletes is subject to U.S. tax if their gross re
in the United States, they are taxed on the profit
Their income is not borne by a permanent
ceipts, including reimbursed expenses, from
attributable to the permanent establishment.
establishment or a fixed base that the em
their entertainment activities in the United
ployer has in the United States.
States are more than $20,000 during the calen
Income that residents of Iceland receive for
dar year. Income of German entertainers or ath
services performed in the United States as em
letes is exempt from U.S. tax if their visit to the
ployees (dependent personal services) is
Page 6
Publication 901 (September 2016)
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