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 19
Students
If a person who is residing in one of the contracting states temporarily exists in another contracting state in the following capacity only:
- (a) as a student in a University, School, Institute or School in such other state.
- (b) as a pupil who receives training on technical or commercial works.
- (c) as a beneficiary of a scholarship, salary or prize from an educational or scientific organization whose prime purpose is to conduct studies and researches.
The said person is not subject to taxes in the other contracting state as concerns the payments remitted to him for the purpose of satisfying the costs of living, education or training or as regards a scholarship. The same provision applies to any amount which constitutes delegation of services that are rendered in such other state on condition that the said services are related to study or training or are necessary for satisfying the costs of living.