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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 20

Students, Teachers and Researchers

(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 other Contracting State, provided that such payments arise from sources outside that other State.

(2) Likewise, remuneration received by a teacher or by an instructor who is or was immediately before visiting a resident of a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State for the purpose of teaching or engaging in scientific research for a period or periods not exceeding two years shall be exempted from tax in that other Contracting State, provided that such payments arise from sources outside that other State.

(3) The provisions of paragraph 2 shall not apply to remuneration and income from research if such research is undertaken for persons and enterprises with business purposes.