background image
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 21

Students

(1) An individual who, immediately before visiting one of the States, is a resident of the other State and is temporarily present in the first-mentioned State for the primary purpose of:

  • (a) studying at a recognized university, college or school in that first-mentioned State, or
  • (b) receiving training as a business apprentice, shall be exempt from tax in the first-mentioned State in respect of:
    • (i) all remittances from abroad for the purpose of his maintenance, education or training, and
    • (ii) any remuneration for personal services performed in the first-mentioned State up to an amount not exceeding 5,000 Dutch guilders or the equivalent thereof in Surinamese guilders in any taxable year.

The benefits under this paragraph shall extend only for such period of time as is reasonable or customarily required to fulfill the purpose of the visit.

(2) An individual who, immediately before visiting one of the States, is a resident of the other State and is temporarily present in the first-mentioned State for a period not exceeding three years for the purpose of study, of scientific research or of training solely as a recipient of a grant, allowance or award from a scientific, educational, religious or charitable organization, or under a technical assistance programme in which one of the two States, a political subdivision or a local authority thereof participates, shall be exempted from tax in the first-mentioned State in respect of:

  • (a) the amount of such grant, allowance or award; and
  • (b) any remuneration for personal services performed in the first-mentioned State, provided such services are in connection with his study, research or training or are incidental thereto up to an amount not exceeding 5,000 Dutch guilders or the equivalent thereof in Surinamese guilders.

(3) An individual who, immediately before visiting one of the States, is a resident of the other State and is temporarily present in the first-mentioned State for a period not exceeding 12 months as an employee of, or under contract with, the last-mentioned State, a political subdivision or local authority thereof or an enterprise of the last-mentioned State, for the purpose of acquiring technical, professional or business experience, shall be exempted from tax in the first-mentioned State on:

  • (a) all remittances from the last-mentioned State for the purpose of maintenance education or training; and
  • (b) any remuneration for personal services performed in the first-mentioned State, provided such services are in connection with his study or training or are incidental thereto up to an amount not exceeding 15,000 Dutch guilders or the equivalent thereof in Surinamese guilders.

However, the benefits under this paragraph shall not be granted if the technical, professional or business experience is acquired from a company of which 50 per cent or more of the voting stock is owned by the State, the political subdivision or the local authority thereof or the enterprise having sent the employee or the person working under contract.