Direct Tax Avoidance Agreements

Zambia

ARTICLE 21 - Research personnel, students and business apprentices - 1.(a) An individual who is a resident of one of the Contracting States at the time he becomes temporarily present in the other Contracting State for the primary purpose of

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

(ii) securing training required to qualify him to practise a profession or professional speciality, or

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

shall be exempt from tax by that other Contracting State with respect to amounts described in sub-paragraph (b) for a period not exceeding 5 taxable years from the date of his arrival in that other Contracting State.

(a) The amounts referred to in sub-paragraph (a) are :

(i)  gifts abroad for the purpose of his maintenance, educational study, research, or training ;

(ii) the grant, allowance, or award ; and

(iii) income from personal services performed in that other Contracting State in an amount not in excess of 1,500 Zambian Kwacha or its equivalent Indian Rupees for any taxable year.

2. An individual who is a resident of one of the Contracting States and who is temporarily present in that other Contracting State as an employee of, or under contract with, a resident of the first-mentioned Contracting, State, for the primary purpose of

(a) acquiring technical, professional, or business experience from a person other than that resident of the first-mentioned Contracting State or other than a person, related to such resident, or

(b) studying at a university or other recognised educational institution in that other Contracting State, shall be exempt from tax in that other Contracting State for a period not exceeding 1 year with respect to his income from personal services in an aggregate amount not in excess of 2,500 Zambian Kwacha or its equivalent Indian Rupees.

3. An individual who is a resident of one of the Contracting States and who is temporarily present in that other Contracting State for a period not exceeding 1 year, as a participant in a programme sponsored by the Government of that other Contracting State, for the primary purpose of training, research, or study, shall be exempt from tax in that other Contracting State with respect to his income from personal services in respect of such training, research, or study performed in that other Contracting State in an aggregate amount not in excess of 3,5000 Zambian Kwacha or its equivalent Indian Rupees.