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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 21

Students and Trainees

(1) An individual who is a resident of a Contracting State and is present on a temporary basis in the other Contracting State only for being:

  • (a) a student at a university, college or school in the other Contracting State;
  • (b) a business, industrial or technical trainee; or
  • (c) a recipient of a scholarship or a prize for the purpose of study or research from a religious, charitable, scientific or educational institution, shall not be taxable in the other Contracting State in respect of such scholarship or prize.

(2) The same provision applies to any amount that represents a reward received by that individual for services rendered in the other Contracting State, provided that these services are pertinent to his study or training and are necessary for maintenance purposes.

(3) Payments which a student or trainee 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 State, provided that such payments arise from sources outside that State.