PROFESSORS OR STUDENTS

-An individual who visits a Contracting State for the purpose of teaching or carrying out
research at a university, college or school or any other officially recognized educational
institution in that State and who is or was immediately before that visit a resident of
the other Contracting State, shall be exempt from taxation (ie in the source source
state) on remuneration for such teaching or research for a period not exceeding two
years from the date of such visit for that purpose –Art 21 (3 ].

- The exemption for teachers can only be obtained if the following are present:
(a) The activities of the teacher must be in respect of educational or research work.
(b) The teaching must be conducted in a recognized educational institution.
(c) The individual’s period of contract must not exceed two years. Any additional year
shall result to all income due to the individual tax in the source state, starting from the
first year.
(d) The research must be of public interest. Where a private entity sponsors the
research, then, care must be taken to ensure that the outcome of the research will not
have direct or indirect benefit to the sponsor.
(e) Where the outcome of the research is sold and it can be concluded that a person
derives a private benefit, any income derives from such venture is taxable.