The Double Taxation Relief (Taxes on Income) (Pakistan) Order 1987

Article 21 Students and trainees

(1) An individual who is a resident of a Contracting State or was a resident of that State immediately before making a visit to the other Contracting State and who is temporarily present in that other State for the primary purpose of:

(a) studying at a university or other recognised educational institution in that other Contracting State; or

(b) securing training required to qualify him to practise a profession or a professional speciality; or

(c) studying or doing research as a recipient of a grant, allowance or award from a governmental, religious, charitable, scientific, literary or educational organisation;

shall not be subject to tax by that other Contracting State with respect to:

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

(ii) remittances from abroad for the purpose of his maintenance, education, study, research or training; and

(iii) income from personal services rendered in that other Contracting State (other than any rendered by an articled clerk or other person undergoing professional training to the person or partnership to whom he is articled or who is providing the training) not exceeding the sum of 750 pounds sterling, or its equivalent in Pakistan rupees as the case may be, during any year of assessment or taxable year.

(2) The benefits under paragraph (1) of this Article shall apply only for such period of time as may be reasonably or customarily required for the purpose of the individual’s visit, but in no event shall any individual have the benefit of that paragraph for more than five years from the date of his first arrival in the other Contracting State.

(3) An individual who is a resident of a Contracting State or was a resident of that State immediately before making a visit to the other Contracting State and who is present in that other State for a period not exceeding twelve months from the date of his first arrival in that other Contracting State in connection with that visit, as a participant in a programme sponsored by the Government of that other Contracting State for the purposes of training, research or study, or 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 from a person other than that Government or that enterprise, shall not be subject to tax by that other Contracting State with respect to:

(a) all remittances from abroad for the purposes of his maintenance, training, research or study; and

(b) any remuneration so far as it does not exceed the sum of 1,500 pounds sterling, or its equivalent in Pakistan rupees as the case may be, during any year of assessment or taxable year for personal services in that other Contracting State in connection with his studies or training.