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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.


Students, Researchers and Apprentices

(1) Payments which a student, researcher or apprentice of one the two Contracting Parties who is visiting the other Contracting State solely for the purpose of his education, training or research receives for the purpose of his maintenance, education, training or research shall not be taxed in that State, provided that such payments arise from sources outside that State.

(2) An individual who was a resident of a Contracting State immediately before visiting the other Contracting State and who is temporarily present in that other State solely for the purpose of his education, research or apprenticeship while receiving a subsidy, allowance or grant from a scientific, educational, religious or charitable organization or under a technical assistance programme in which the Government of a Contracting State participates shall be exempt, from the date of his initial arrival in that other State in connection with his visit from any tax applying in that State to:

  • (a) The amount of that subsidy, allowance or grant, and
  • (b) Payments from abroad for his maintenance, education or training.