ARTICLE 21
STUDENTS AND APPRENTICES 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 education. ARICLE 22
INCOME NOT EXPRESSLY MENTIONED 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. ARTICLE 23
ELIMINATION OF DOUBLE TAXATION 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. ARTICLE 24
NON-DISCRIMINATION 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. ARTICLE 25
MUTUAL AGREEMENT PROCEDURE 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. | 
