ARTICLE 19
An individual who is, or immediately before visiting a
Contracting State was, a resident of the other Contracting State
and is temporarily present in the first-mentioned Contracting
State for the primary purpose of teaching, giving lectures or
conducting research at a university, college, school or other
accredited educational institution or scientific research
institution in the first-mentioned Contracting State shall be
exempt from tax in the first-mentioned Contracting State for a
period not exceeding three years in the aggregate in respect of
remuneration for such teaching, lectures or research.
ARTICLE 20
A student, business apprentice or trainee who is or was
immediately before visiting a Contracting State, a resident of the
other Contracting State and who is present in the first-mentioned
Constracting State solely for the purpose of his
education, training or obtaining special technical experience
shall be exempt from tax in that Contracting State with
respect to:
(a) payments received from abroad for the purpose of his
maintenance, education, study, research or training;
(b) grants or awards from a government, scientific, educational
or other tax-exempt organization; and
(c) income from personal services performed in that Contracting
State in an amount not in excess of 5,000 United States
dollars or its equivalent in Chinese yuan for any taxable year.
The benefits provided under this Article shall extend only for
such period of time as is reasonably necessary to complete
the education or training.