МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 17
                        Artists and sportsmen

     1.  Notwithstanding  the provisions of Articles 14 and 15, income
derived  by  a resident of a Contracting State as an entertainer, such
as  a  theater,  motion  picture,  radio  or  television artiste, or a
musician,  or  as  a  sportsman,  from his personal activities as such
exercised  in  the other Contracting State, may be taxed in that other
State.
     2. Where income in respect of personal activities exercised by an
entertainer  or a sportsman in his capacity as such accrues not to the
entertainer  or  sportsman  himself but to another person, that income
may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed
in the Contracting State in which the activities of the entertainer or
sportsman are exercised.
     3. The provisions of paragraphs 1 and 2 shall not apply to income
derived   from   activities   performed  in  a  Contracting  State  by
entertainers  or sportsmen if the visit to that State is substantially
supported  by  public  funds  of  the  other  Contracting  State  or a
political subdivision or a local authority thereof. In such a case the
income  shall be taxable only in the State of which the entertainer or
sportsman is a resident.