Student and trainee tax exemptions protect gifts, grants and limited personal service income during temporary visits under the tax treaty. Article 21 provides that residents temporarily present in the other Contracting State as students, trainees, researchers on grants, or persons obtaining professional training are not taxable by the visited State on gifts from abroad for maintenance, grants or allowances, and limited income from personal services (with specified exclusions). Exemptions are limited to the period reasonably required for the visit, capped at five years, and include separate 12 month rules for employees acquiring experience or participating in government sponsored programmes.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Student and trainee tax exemptions protect gifts, grants and limited personal service income during temporary visits under the tax treaty.
Article 21 provides that residents temporarily present in the other Contracting State as students, trainees, researchers on grants, or persons obtaining professional training are not taxable by the visited State on gifts from abroad for maintenance, grants or allowances, and limited income from personal services (with specified exclusions). Exemptions are limited to the period reasonably required for the visit, capped at five years, and include separate 12 month rules for employees acquiring experience or participating in government sponsored programmes.
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