Part Article 20

Subject to paragraph (2) of this Article, an individual who visits one of the Contracting States for a period not exceeding two years for the purpose of teaching or engaging in research at a university, college, school or other recognised educational institution in that Contracting State, and who immediately before that visit was a resident of the other Contracting State, shall be taxable only in that other State on any remuneration for such teaching or research for a period not exceeding two years from the date he first visits that State for such purpose.

Where, under the provisions of this Convention taken together with the law in force in the other State, a teacher or researcher referred to in paragraph (1) of this Article is exempt from tax in that other State on his remuneration, or is entitled to a deduction equal to that remuneration in computing his liability to tax in that other State, such remuneration shall be taxable only in the first-mentioned State.

The provisions of this Article shall apply to income from research only if such research is undertaken by the individual in the public interest and not primarily for the benefit of a private person or persons.