The “Teachers and Researchers” Article in Tax Treaties

To promote international communication and cooperation in the field of educational or academic activities, foreign teachers and researchers who work for Chinese universities or scientific research institutions generally receive an income tax exemption pursuant to the “Teachers and Researchers” Article in tax treaties. The author analyses the origin, application and implementation of the Article from China’s perspective, and asks if this Article differs from the “Students” Article. It also considers the interpretation of and the obstacles to, from the point of view of China’s domestic law, the application of the Article.