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HMRC internal manual

International Manual

Description of double taxation agreements: Students

The provisions of this Article vary considerably from agreement to agreement. The basic provision, which is common to all agreements, is that a student or business apprentice, who immediately before coming to one country was a resident of the other country, and is present in the first country solely for the purpose of their education or training, is exempt from the first country’s tax on any payments they receive from outside that country for the purpose of their maintenance, education or training. Other provisions, which may or may not be included, cover remuneration to supplement the student’s resources from employment in the country visited subject, in some agreements, to specified monetary limits, exclude remuneration as articled clerks, or impose a limit on the number of years for which the exemption can be claimed.