ARTICLE 21
Students, Trainees, Teachers, and Researchers
(1)
- (a) An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other Contracting State for the primary purpose of:
- (i) studying at a university or other accredited educational institution in that other Contracting State, or
- (ii) securing training required to qualify him to practice a profession or professional specialty, or
- (iii) studying or doing research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization,
- shall be exempt from tax by that other Contracting State with respect to the amounts described in sub-paragraph (b) of this paragraph for a period not exceeding five years from the date of his arrival in that other Contracting State.
- (b) The amounts referred to in sub-paragraph (a) of this paragraph are:
- (i) payments from abroad, other than compensation for personal services, for the purpose of his maintenance, education, study, research, or training;
- (ii) the grant, allowance, or award; and
- (iii) income from personal services performed in that other Contracting State in an aggregate amount not in excess of 5,000 United States dollars ($5,000)or its equivalent in Czech crowns for any taxable year.
(2) An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other Contracting State as an employee of, or under contract with, a resident of the first-mentioned Contracting State, for the primary purpose of:
- (a) acquiring technical, professional, or business experience from a person other than that resident of the first-mentioned Contracting State, or
- (b) studying at a university or other accredited educational institution in that other Contracting State,
shall be exempt from tax by that other Contracting State for a period of 12 consecutive months with respect to his income from personal services in an aggregate amount not in excess of 8,000 United States dollars ($8,000) or its equivalent in Czech crowns.
(3) An individual who is a resident of one of the Contracting States at the time he becomes temporarily present in the other Contracting State and who is temporarily present in the other Contracting State for a period not exceeding 1 year, as a participant in a program sponsored by the Government of that other Contracting State, for the primary purpose of training, research, or study,shall be exempt from tax by that other Contracting State with respect to his income from personal services in respect of such training, research, or study performed in that other Contracting State in an aggregate amount not in excess of 10,000 United States dollars ($10,000) or its equivalent in Czech crowns.
(4) The competent authorities of the Contracting States may agree to change the amounts specified in paragraphs 1(b) (iii), 2 (b), and 3 of this Article to reflect significant changes in price levels.
(5) An individual who visits a Contracting State for the primary purpose of teaching or conducting research at a university, college, school or other accredited educational or research institution in the other Contracting State, and who is, or immediately before such visit was, a resident of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State for a period not exceeding two years in respect of remuneration for such teaching or research. The benefits provided in this paragraph shall not be granted to an individual who, during the immediately preceding period enjoyed the benefits of one of the preceding paragraphs of this Article. An individual shall be entitled to the benefits of this paragraph only once.
(6) This Article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons.