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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.


Teachers and Researchers

(1) Notwithstanding the provisions of Article 15 of this Convention, the remuneration paid to a teacher or a researcher, who is or was immediately before visiting a Contracting State, a resident of the other Contracting State and who, upon invitation, is present in the first-mentioned State for the sole purpose of teaching or for carrying out research work, in a university, or any other officially recognized teaching institution, shall not be taxable in the first mentioned State for a period not exceeding two years from the date of arrival of such person in that State, as long as such remuneration arises from sources situated outside that State.

(2) The provisions of paragraph (1) of this Article, shall not apply to remuneration received in respect of research work carried out not in general interest but mainly in the private interest of one or several specified persons.