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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 22

Students and Business Apprentices

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/her maintenance, education or training shall not be taxed in that State:

  • (a) payment derived from sources outside for the purpose of his/her maintenance, education, study or training; and
  • (b) notwithstanding the provisions of Articles 15 and 16, payment, not exceed U.S. $4,000 or equivalent in currency of the Contracting State, derived from service activities of that person in a taxable year.