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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) The individual who is a resident of a Contracting State, and is present on a temporary basis in the other Contracting State only for the education and training at a university, college or school, shall not be taxable in the other Contracting State in respect of his scholarship.

(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 received by an individual who is a resident of a Contracting State and immediately moves to the other Contracting State for the purpose of education, training or carrying out research, shall not be taxable in this last case, provided that such payments arises from sources outside that State.