ARTICLE 19
Students, Teachers and Professors
(1) Payments which a student, apprentice or business trainee 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 the first-mentioned State, provided that such payments arise from sources outside that State.
(2) Likewise, remuneration received by a teacher or a professor who visits a Contracting State for a period not exceeding two years as of the date he first visits that Contracting State and who is or was immediately before that visit a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of teaching or engaging in scientific research at a university, college or other recognised research institute or other establishments for higher education in that Contracting State shall be exempted from tax in that State, provided that the sources of such payments are in the other Contracting State.
This paragraph shall not apply to remuneration and income from research if such research is undertaken for enterprises with business purposes.