The OECD-Model-Convention and its Update 2014
1. Aufl. 2015
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I. S. 100Introduction
“Payments which a student or business apprentice 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 State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.”
Containing just one paragraph, article 20 is one of the shortest provisions in the OECD Model Convention (OECD Model). Despite – or probably because of – its brevity, there are many unresolved issues and deviating interpretations concerning this article.
Article 20 stipulates that one contracting state, the state where a student or business trainee currently stays for educational purposes, may not tax certain payments. The one contracting state where the student or business trainee pursues his or her education will, for purposes of this chapter, be referred to as the host state. The other contracting state will be denoted as the state of origin. For simplicity, throughout this chapter, only the term “student” will be used and will be understood as referri...