The "teachers and researchers" article in Singapore's tax treaties

Some tax treaties have a separate article dealing specifically with visiting teachers and researchers which provides a tax exemption in the state of source ("state of visit") for such individuals. The main purpose of such a provision is to stimulate the cross-flow of academics, not so much to allocate taxing rights. A "teachers and researchers" provision is included in more than half of Singapore's 51 tax treaties, reflecting Singapore's desire to be a premier education hub. This article looks at the policy considerations and evaluates some interpretative aspects of the teachers and researchers provision from Singapore's perspective.