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HMRC internal manual

Double Taxation Relief Manual

DT: Philippines: double taxation agreement, Article 19: Students and trainees

 

(1) An individual who was a resident of a Contracting State immediately before making avisit to the other Contracting State and is temporarily present in that other State solely as a student at a university, college, school or other similar recognised educational institution in that other State or as a business apprentice there in, shall be exempt from tax in that other State on:

 

  1. all remittances from abroad for the purpose of his maintenance, education or training; and
  2. any income derived from the other Contracting State in respect of services rendered in that other State (other than any rendered by a business apprentice to the person or partnership to whom he is apprenticed), with a view to supplementing the resources available to him for such purposes, not exceeding the sum of 500 pounds sterling in the case of the United Kingdom, or the equivalent in Philippine currency in the case of the Philippines, during any year of assessment.

(2) An individual who was a resident of a Contracting State immediately before making avisit to the other Contracting State and is temporarily present in that other State,solely for the purposes of study, research or training as a recipient of a grant, allowance or award from a scientific, educational, religious or charitable organisation or under a technical assistance programme entered into by the Government of either of the Contracting States shall be exempt from tax in that other State on:

  1. the amount of such grant, allowance or award; and
  2. all remittances from abroad for the purposes of his maintenance, education or training.

(3) The exemptions from tax provided under paragraphs (1) and (2) of this Article shall apply only for such period of time as may reasonably or customarily be required for the purpose of the individual’s visit but no individual shall be entitled to such exemptions for more than five years from the date of his first arrival in the other Contracting State.