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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Tunisia: double taxation agreement, Article 20: Students and trainees

(1) An individual who is or was a resident of a Contracting State immediately before making a visit to the other Contracting State and who is temporarily present in that other Contracting State for the primary purpose of:

(a) studying at a university or other recognised educational institution in that other Contracting State; or

(b) securing training required to qualify him to practise a profession or a professional speciality; or

(c) studying or doing research as a recipient of a grant, allowance, or award (not including a salary or part salary) from a government, religious, charitable, scientific, literary or educational organisation;

shall be exempt from tax in that other Contracting State on:

(i) the amount of such grant, allowance or award;

(ii) remittances from abroad for the purpose of his maintenance, education, study, research or training; and

(iii) income from personal services rendered in that other Contracting State (other than any rendered by an articled clerk or other person undergoing professional training to the person or partnership to whom he is articled or who is providing the training) not exceeding the sum of £750 sterling in the case of the United Kingdom or the equivalent in Tunisian dinars in the case of Tunisia during any year of assessment or taxable year.

(2) The exemptions from tax provided under paragraph (1) of this Article shall apply only for such period of time as may be reasonably or customarily required for the purposeof the individual’s visit, but in no event shall any individual have the benefit of that paragraph for more than five consecutive years from the date of his first arrival in the other Contracting State.

(3) An individual who is or was a resident of a Contracting State immediately before making a visit to the other Contracting State and who is present in the other Contracting State for a period not exceeding twelve months from the date of his first arrival in that other Contracting State in connection with that visit, as a participant in a programme sponsored by the Government of that other Contracting State for the purposes of training, research or study, or as an employee of or under contract with the Government or an enterprise of the first- mentioned Contracting State for the purpose of acquiring technical, professional or business experience from a person other than that Government or that enterprise, shall be exempt from tax in that other Contracting State on:

(a) all remittances from abroad for the purposes of his maintenance, training, research or study; and

(b) any remuneration so far as it does not exceed £1,200 sterling, or its equivalent in Tunisian dinars as the case may be, during any year of assessment or taxable year for personal services in that other Contracting State in connection with his studies or training.