1) An individual who visits a Contracting State for a period not exceeding two years for the purpose of teaching or engaging in research at a university, college, school, museum or other cultural or educational institution of that State or under an official programme of cultural exchange and who is, or was immediately before that visit, a resident of the other Contracting State shall be exempt from tax in the first‑mentioned State on his remuneration for such activity, provided that such remuneration is derived by him from outside that State.
2) Payments which a student or business apprentice 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.