ARTICLE 21
Students and trainees
1. An individual who is a resident of a Contracting State or was a resident of that State
immediately before visiting the other Contracting State and who is temporarily present in
that other State for the primary purpose of:
a) studying at a university or other accredited or recognised educational institution in
that other Contracting State; or
b) securing training required to qualify him to practise a profession or a 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 organisation;
shall not be subject to tax by that other Contracting State in respect of:
(i) gifts from abroad for the purposes of his maintenance, education, study,
research or training;
(ii) the grant, allowance or award; and
(iii) income from personal services rendered in that other Contracting State
(other than any rendered by an article clerk or other person undergoing
professional training to the person or partnership to whom he is articled or
who is providing the training) not exceeding the sum of 750 pounds
sterling or its equivalent in Indian currency during any fiscal year.
3. An individual who is a resident of a Contracting State or was a resident of that State
imediately before visiting the other Contracting State and who is temporarily present in that
other State for a period not exceeding 12 months, as an employee of, or under contract with,
a resident of the first-mentioned Contracting State, for the primary purpose of:
a) acquiring technical, professional or business experience from a person other than that
resident of the first-mentioned Contracting State; or
b) studying at a university or other accredited or recognised institution in that other
Contracting State;
shall not be subject to tax by that other Contracting State on his income from personal
services performed in the other Contracting State for that period in an amount not exceeding
1,500 pounds sterling or its equivalent in Indian currency.
4. An individual who is a resident of a Contracting State or was a resident of that State
immediately before visiting the other Contracting State and who is temporarily present in
that other State for a period not exceeding 12 months as a participant in a programme
sponsored by the Government of the other Contracting State, for the primary purpose of
training, research or study, shall not be subject to tax by that other Contracting State in
respect of payments made by the Government of the first-mentioned Contracting State for
the purposes of his maintenance, training, research, or study.