An individual who, immediately before visiting a Contracting State, was  a resident of the other Contracting State and is temporarily present in the first mentioned Contracting State solely-

            (a)        as a student at a recognized university, college or school in

                         the  first-mentioned State; or

            (b)        as a business apprentice; or

            (c)        as  the recipient of a grant, allowance or award for the

                         primary  purpose  of  study  or  research  from a

                         governmental, religious,  charitable, scientific, literary or

                         educational organization,shall be exempt from tax in the first-

                         mentioned State in respect  of-

                         (i)         the remittances from abroad for the purpose of his

                                      maintenace, education, study, research or training;

                         (ii)        the grant, allowance or award; and

                         (iii)       the remuneration from employment in that State

                                      provided the  remuneration  constitutes earnings

                                      reasonably necessary for  his maintenance and





            Items  of  income  of a resident of a Contracting State which are not expressly mentioned in the foregoing Articles of this Convention may be taxed in  the Contracting State where the income arises.




1.         the laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except when express  provision  to the contrary is made in this Convention. When income is  subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this Article.


2.         Tax payable in a Contracting State in respect of income derived from  that  State shall be allowed as a credit against any tax payable in the other  Contracting  State  in  respect of that income. The credit shall not, however,  exceed that part of the tax payable in the other Contracting State as computed  before the credit is given, which is appropriate to such item of income.


3.         For the purpose of allowance as a credit in a Contracting state the tax paid in the other Contracting State shall be deemed to include the tax which  is  otherwise  payable  in that other State but has been reduced or waived in  accordance  with  the  special  incentive  laws  designed  to promote economic  development in that other State.




1.         Nationals of a Contracting State shall not be subjected in the other  Contracting  State  to any taxation or any requirement connected therewith is  other or more burdensome than the taxation and connected requirements to which  the  nationals  of  that  other  State  in the same circumstance are or may be  subjected.


 2.        The enterprises of a Contracting State shall not be subjected in the other Contracting State, in respect of profits attributable to their permanent establishments  in  that  other  State, to any taxation which is other or more  burdensome than the taxation to which the enterprise of that other State, are or may be subjected in respect of the like profits.


3.         In  this  Article  the  term "taxation" means taxes which are the  subject of this Convention.


4.         Nothing  in  this  Article  shall be construed as obliging either  Contracting  State to grant to residents of the other Contracting State, those  personal allowances, reliefs and reductions for tax purposes which it grants to  its own residents.




1.         Where a resident of a Contracting State considers that the actions of  one  or  both  of  the Contracting States result or will result for him in  taxation not  in accordance with this Convention, he may notwithstanding the  remedies by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented  within three years from the notification of the action resulting in  taxation not in accordance with the provisions of this Convention.


2.         The competent authority shall endeavour, if the objection appears to it  to  be justified and if it is not itself able to arrive at a satisfactory  solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State with a view to the avoidance of taxation not in  accordance with the Convention.


3.         The competent authorities of the Contracting States shall endeavour  to  resolve  by mutual agreement any difficulties or doubts arising as to the  interpretation or application of the Convention. They may also consult together  for  the  elimination  of  double  taxation in cases not provided for in this  Convention.


4.         The competent authorities of the Contracting States may communicate  with each other directly for the purposes of reaching an agreement in the sense of the preceding paragraphs.




Last updated: 08.12.2011