ARTICLE 16 Teachers 1. An individual who is a resident of one of the Contracting States at the beginning of his visit to the other Contracting State and who, at the invitation of the Government of the other Contracting State or of a university or other accredited educational institution situated in the other Contracting State, visits the latter Contracting State for the primary of teaching or engaging in research, or both, at a university or other accredited educational institution shall be exempt from tax by the latter Contracting State on his income from personal services for teaching or research at such educational institution, or at other such institutions, for a period not exceeding two years from the date of his arrival in the latter Contracting State. 2. This Article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit or interest of a specific person or persons. ARTICLE 17 Students and Trainees 1. An individual who is a resident of one of the Contracting States at the beginning of his visit to the other Contracting State and who is temporarily present in the other Contracting State for the primary purpose of (a) studying at a university or other accredited educational institution in that other Contracting State, or (b) securing training required to qualify him to practice a profession or professional speciality, or (c) studying or doing research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary or educational organization, shall be exempt from tax in that other Contracting State with respect to (i) remittance from abroad for the purposes of his maintenance, education, study, research or training; (ii) the grant, allowance, or award. The same shall apply to any amount representing remuneration for services rendered in the other Contracting State, provided that such services are in connection with his studies or training or are necessary for the purpose of his maintenances. However this clause shall not apply to such cases in which the studies or practices have a secondary character in respect of services rendered that are producing the said remuneration. 2. The benefits under the provisions of paragraph (1) of this Article shall only extend for such period of time as may be reasonably or customarily required to effectuate the purpose of the visit, but in no event shall any individual have the benefits of this paragraph for more than five consecutive years. 3. An individual who is a resident of one of the Contracting States at the beginning of his visit to the other Contracting State and who is present in the other Contracting State for a period not exceeding one year, as an employee of, or under contract with, a resident or corporation of the former State, for the primary purpose of acquiring technical, professional, or business experience from a person other than that resident or corporation of the former State shall be exempt from tax in that other Contracting State with respect ot his income from personal services performed in the other Contracting State for that period, provided that such services are in connection with the purposes as above mentioned. 4. An individual who is a resident of one of the Contracting State at the beginning of his visit to the other Contracting State and who is present in the other Contracting State for a period not exceeding one year, as a participant in a program sponsored by the Government of the other Contracting State, for the primary purpose of training, research or study, shall be exempt from tax in that other Contracting State with respect to his income from personal services performed in that other Contracting State in connection with such training, research, or study. ARTICLE 18 Governmental Salaries Wages, salaries, or similar compensation and pensions, annuities, or similar benefits paid by, or from funds created by, one of the Contracting States (including local authorities thereof) to an individual who is a national of that Contracting State for services rendered to that Contracting State or to any of its local authorities in the discharge of governmental functions shall be exempt from tax in the other Contracting State. ARTICLE 19 Diplomatic and Consular Privileges Nothing in this Convention shall affect the fiscal privileges of diplomatic or consular officials under the general rules of international law or under the provisions of special agreements. ARTICLE 20 Rules Applicable to Personal Income Articles An individual who qualifies for benefits under more than one provisions of Articles 15, 16, 17 and 18 may apply the provision most favourable to him, but he shall not be entitled to the benefits of more than one provision in any taxable year or taxable period. |