ARTICLE 19
Teachers, Students 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 Contracting 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 Contracting State, provided that such payments arise from sources outside that Contracting State.
(2) Likewise, remuneration received by a teacher or by an instructor 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 Contracting 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 the first-mentioned Contracting State, provided that such payments arise from sources outside that Contracting State. This paragraph shall not apply to remuneration and income from research if such research is undertaken for persons and enterprises with business purposes.