ARTICLE 21

Students and Trainees

1. Payments which a student, 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 for the purpose of his full-time 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 outside that State.

2. An individual who is a resident of a Contracting State at the time he becomes temporarily present in the other Contracting State and who is temporarily present in that other Contracting State as an employee or, 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 a person related to such resident; or

(b) studying at a university or other recognized educational institution in that other State, shall be exempt from tax by that other Contracting State for a period not exceeding 12 consecutive months with respect to his net income from personal services in an amount not in excess of 7,500 United States dollars or its equivalent in Jamaican dollars for any taxable year.

3. Notwithstanding Article 4 (Residence), an individual to whom paragraph 1 or 2 applies and who immediately before visiting or becoming temporarily present in a Contracting State was a resident of the other Contracting State may elect as an alternative to the provisions of those paragraphs to be treated for all tax purposes of the first-mentioned State including this Convention, as a resident of that State. The election shall apply to all periods during the taxable year of the election and subsequent taxable years during which the individual qualifies under paragraph 1 or 2 and may not be revoked except with the consent of the competent authority of that State.