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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 21

Students

(1) Payments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned Contracting State solely for the purpose of his education or training receives for the purpose of his maintenances, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.

(2) Notwithstanding the provisions of paragraph l, remuneration which a student or business apprentice who is or was immediately before visiting a Contracting state a resident of the other Contracting State and who is present in the first-mentioned Contracting State Solely for the purpose of his education or training derives form temporary services rendered in that other Contracting State, shall not be taxed in that other state provided that such services are in connection with his education or training and that the remuneration for such services is necessary to supplement the resources available to him for the purpose of his maintenance.