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Aircraft Pilots and Drone Operators under Tax Treaties: Air Show Performances, Technical Services and the Limits of Article 17

Karolina Tetłak

Bulletin for International Taxation2026https://doi.org/10.59403/130gccgarticle
ABDC B
Weight
0.50

Abstract

This article examines the treaty classification of income earned by aircraft pilots and drone operators in air show performances. It distinguishes between competitive air-sport events, non-competitive demonstration displays and record-style stunt performances, and argues that article 17 applies only in cases in which pilots or drone operators participate in formal rule-based sporting competitions.

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https://doi.org/https://doi.org/10.59403/130gccg

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@article{karolina2026,
  title        = {{Aircraft Pilots and Drone Operators under Tax Treaties: Air Show Performances, Technical Services and the Limits of Article 17}},
  author       = {Karolina Tetłak},
  journal      = {Bulletin for International Taxation},
  year         = {2026},
  doi          = {https://doi.org/https://doi.org/10.59403/130gccg},
}

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Aircraft Pilots and Drone Operators under Tax Treaties: Air Show Performances, Technical Services and the Limits of Article 17

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.