Article 21 - Professors, teachers and students - Namibia

ARTICLE 21 PROFESSORS, TEACHERS AND STUDENTS 1. Remuneration received for education or scientific research by an individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State for the purpose of scientific research or for teaching at an educational institution shall be exempt from tax in the first-mentioned State. This exemption shall be granted for a period that shall not exceed two years from the date on which the teacher or researcher first entered the first-mentioned State for the purposes of engaging in scientific research or for teaching. This article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons. 2. (a) Payments which a student or a business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State. (b) Payments which a student or business apprentice receives as remuneration from employment in the first-mentioned State shall be exempted from tax in the first-mentioned State. This benefit shall extend only for such period of time as may be reasonable or customarily required to complete the education or training undertaken, but in no event shall any individual have the benefit of this provision for more than three consecutive years from the date of his or her first arrival in the first-mentioned Contracting State.