background image
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.



(1) Payments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State, and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from the sources outside that State.

(2) The terms "student" or "business apprentice" mean a resident of a Contracting State, who stays temporarily in the other Contracting State for only one of these reasons:

  • (a) he is a student at a university, college or school in the other Contracting State;
  • (b) he is a business apprentice in industrial or commercial business, or a technical apprentice;
  • (c) he already has a scholarship for study or research from a religious, charitable, scientific or educational body.