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HMRC internal manual

Double Taxation Relief Manual

DT: Thailand: double taxation agreement, Article 20: Students

(1) An individual who, immediately before visiting a Contracting State, was a resident of the other Contracting State and whose visit to the first-mentioned Contracting State is solely for the purpose of:

(a) studying at a university or other recognised educational institution; or
(b) securing training to qualify him to practise a profession or trade; or
(c) studying or carrying out research as a recipient of a grant, allowance or award from a governmental, religious, charitable, scientific, literary or educational organisation;

shall be exempt from tax in the first-mentioned State on:

(i) remittances from abroad for the purposes of his maintenance, education, study, research or training;
(ii) the grant, allowance or award; and
(iii) income from personal services rendered in that State (other than services rendered by an articled clerk, or other individual undergoing training, to the person or partnership to whom he is articled or who is providing the training) provided the income constitutes earnings reasonably necessary for his maintenance and education.

(2) In no event shall an individual have the benefit of the provisions of paragraph (1)(iii) of this Article for more than five years.