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 22
STUDENTS
Student, business apprentice or trainee 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 State solely for the purpose of his education or training is no subject to taxes on:
- (a) amounts received for the purpose of his maintenance, education or training provided that such payments arise from sources outside that State.
- (b) revenue derived from a function in the other Contracting State only if this function is related to his education or training and this revenue is necessary for his living.
Nevertheless, the provisions of this paragraph shall apply only within the normal period of the studies in the case of a student, and during the period for training in the case of training. And the function is in relation with the training in the other Contracting State.