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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Kenya: double taxation agreement, Article 22: Students

  1. A student or 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 Contracting State solely for the purpose of his education or training shall be exempt from tax in that first-mentioned Contracting State on:

a. payments made to him by persons residing outside that first-mentioned Contracting State for the purposes of his maintenance, education or training; and

b. remuneration from employment in that first-mentioned Contracting State provided that the remuneration constitutes earnings reasonably necessary for his maintenance and education.

  1. The benefits of this Article shall extend only for such period of time as may be reasonably or customarily required to complete the education or training undertaken but in no event shall any individual have the benefits of this Article for more than three consecutive years.