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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 and Apprentices

(1) An individual who is a resident of one of the Contracting State and is temporarily present in the other Contracting State solely:

  • (a) as a student at a recognised university, college or school in that other Contracting State, or
  • (b) as a business apprentice, or
  • (c) as the recipient of a grant, allowances, or award for the primary purpose of study or research from a governmental, religious, charitable, scientific, literary or educational organisation, shall not be subjected to tax in that other Contracting State:
    • (aa) on the remittances from abroad for the purposes of his maintenance, education, training, study or research; and
    • (bb) the grant, allowance or award.

(2) For the purposes of this Article and Article 21, an individual shall be deemed to be a resident of a Contracting State if he is resident in that Contracting State in the "previous year" or calendar year, as the case may be, in which he visits the other Contracting State or in the immediately preceding "previous year" of calendar year.