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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Zambia: double taxation agreement, Article 21: Research personnel and students

 

(1) An individual who immediately before visiting one of the Contracting States is a resident of the other Contracting State and is temporarily present in the firstmentioned Contracting State for a period not exceeding two years for the purpose of research, solely 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 one of the Contracting States shall be exempt from tax in the first-mentioned Contracting State on-

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

(b) any remuneration for personal services rendered in the first-mentioned Contracting State provided such services are in connection with his research or are incidental thereto.

(2) Payments which a student or business apprentice who is or was formerly a resident of a Contracting State and who is present in the other Contracting 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 other Contracting State provided that such payments are made to him from sources outside that other Contracting State.

(3) Remuneration which a student or business apprentice who is or was formerly a resident of a Contracting State derives from an employment which he exercises in the other Contracting State shall not be taxed in that other Contracting State provided that such employment is directly related to his studies or training or the remuneration constitutes earnings reasonably necessary for his maintenance and education.

(4) The benefits of paragraphs (2) and (3) 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 of assessment or charge years.