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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) An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other State solely as a student at a university, college, school or other similar educational institution in that other State or as business, agricultural, forestry or technical apprentice (including in the case of the Federal Republic of Germany a Volontar or a Praktikant) shall, from the date of his first arrival in that other State in connection with that visit, be exempt from tax in that other State on:

  • (a) all remittances from abroad for purposes of his maintenance, education or training, and
  • (b) for a period not exceeding in the aggregate three years, on any remuneration not exceeding 7200 DM or the equivalent in Portuguese currency for the calendar year, for personal services rendered in that other State with a view to supplement the resources available to him for his maintenance, education or training.

(2) An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other Contracting State solely for the purpose of study, research or training as a recipient of a grant, allowance or award from a scientific, educational, religious or charitable organization or under a co-operation program entered into by the Government of a Contracting State shall from the date of his first arrival in that other State be exempt from tax in that State:

  • (a) on the amount of such grant, allowance or award;
  • (b) on all remittances from abroad for the purposes of his maintenance, education or training; and
  • (c) for a period not exceeding in the aggregate three years, on any remuneration not exceeding 7200 DM or the equivalent in Portuguese currency for the calendar year, for personal services rendered in that other State with a view to supplement the resources available to him for his maintenance, education or training.

(3) A resident of one of the contracting States who is an employee of, or under a contract with, an enterprise of such State or an organization described in paragraph (2) of this Article, and who is temporarily present in the other Contracting State for a period not exceeding one year solely to acquire technical, professional or business experience from any person other than such enterprise or organization, shall be exempt from tax by such other State on compensation for services wherever performed unless the amount thereof exceeds 15,000 DM or equivalent in Portuguese currency.