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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 received by a student or a trainee who is (or was) before visiting a Contracting State, a resident in the other Contracting State and is currently present in the first mentioned Contracting State only for the purpose of his education or training, as well as payments that are for the purpose of his living, education or training shall not be taxable in that State provided that such payments are from resources outside the State, However, scholarships and other grants are not taxable in either Contracting State.

(2) Which a student or trainee who, prior to his visit to a Contracting State, was/or is directly a resident of the other Contracting State earns because of an employment in the first-mentioned State for a period or periods not exceeding in the aggregate (183) days in the financial year concerned shall not be taxed in the first-mentioned State if employment is directly related to his studies or training in that other country.