(1) An individual who visits a Contracting State at the invitation of that State or of a
university‚ college‚ school‚ museum or other cultural institution of that State or under an
official programme of cultural exchange for a period not exceeding in the aggregate two
years from the date of first arrival in that State solely for the purpose of teaching‚ giving
lectures or carrying out research at such institution 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 remuneration for such activity‚ provided that such remuneration
is derived by the individual from outside that State.
(2) A student or business apprentice who is present in a Contracting State solely for the
purpose of the student or business apprentice’s education or training and who is‚ or
immediately before being so present was‚ a resident of the other Contracting State‚ shall be
exempt from tax in the first-mentioned State on payments received from outside that
first-mentioned State for the purposes of the maintenance‚ education or training of that
student or business apprentice.