ARTICLE 21Teachers and researchers
(1) Subject to paragraph (2) of this Article, an individual who, at the invitation of a public university or college, or an institution which exists primarily for research purposes or a similar public institution, visits a Contracting State for a period not exceeding two years solely for the purpose of teaching or engaging in research or both at such public institution, and who immediately before that visit was a resident of the other Contracting State, shall be exempt from tax in the first-mentioned 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.
(2) Where, under the provisions of this Agreement taken together with the law in force in the State where the individual has been a resident, a teacher or researcher referred to in paragraph (1) of this Article is exempt from tax in that State on his remuneration, or is entitled to a deduction equal to that remuneration in computing his liability to tax in that State, such remuneration shall be taxable only in the other State.
(3) The provisions of this Article shall apply to income from teaching or research only if that teaching or research is undertaken by the individual in the public interest and not primarily for the benefit of some other private person or persons.