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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) 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 State solely for the purpose of that person's education or training shall be exempt from tax in that first-mentioned State in respect of:

  • (a) payments from sources outside the first-mentioned Contracting State for the purpose of that person's maintenance, education or training; or
  • (b) grants, allowances or awards from a government of a Contracting State or public foundation for the purpose of that person's maintenance, education or training.

(2) In no case shall any person have the benefit of the provisions of paragraph 1 of this Article for more than five fiscal years.