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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Cyprus: double taxation agreement, Article 21: Students and trainees

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

(a) all remittances from the first-mentioned Contracting State for the purposes of his maintenance, education or training; and
(b) any income not exceeding the sum of £600 sterling in the case of the United Kingdom or the equivalent in Cyprus pounds in the case of Cyprus during any year of assessment, which is derived from the other Contracting State in respect of services rendered in that other Contracting State (other than any rendered by a business or technical apprentice to the person or partnership to whom he is apprenticed), with a view to supplementing the resources available to him for such purposes. Where the income exceeds that sum the excess shall be taxable in accordance with the law of that other State.
(2) An individual who is or was a resident of one of the Contracting States immediately before making a visit to the other Contracting State and is temporarily present in that other Contracting State for the purposes of study, research or training solely as a recipient of a grant, allowance or award from the Government of either of the Contracting States or 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, for a period not exceeding four years from the date of his first arrival in that other Contracting State in connection with that visit, be exempt from tax in that other Contracting State on:

(a) the amount of such grant, allowance or award; and
(b) any income derived from that other Contracting State in respect of services in that other Contracting State if the services are performed in connection with his study, research, training or are incidental thereto.
(3) An individual who is or was a resident of one of the Contracting States immediately before making a visit to the other Contracting State and is temporarily present in that other Contracting State solely 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 for a period not exceeding two years from the date of his first arrival in that other Contracting State in connection with that visit shall be exempt in that other Contracting State on:

(a) all remittances from the first-mentioned Contracting State for the purposes of his maintenance, education or training; and
(b) any remuneration, not exceeding £1,200 sterling or the equivalent in Cyprus pounds, as the case may be, for personal services rendered in that other Contracting State, provided such services are in connection with his studies or training or are incidental thereto. Where the remuneration exceeds that sum the excess shall be taxable in accordance with the law of that other State.
(4) In this Article, references to a Government shall include references to a statutory body established in a Contracting State in order to carry on a public utility undertaking under national control.