ARTICLE 20

Teachers and Researchers

This Article provides that an individual resident of a Contracting State who is invited by a university, school, or similar educational institution to visit the other Contracting State for the purpose of teaching and/or doing research at that educational institution, is exempt from tax by that other State on the remuneration for such teaching or research for up to two years from his date of arrival in the other State. Although the reference to "recognized" educational institutions found in similar provisions in other U.S. treaties and in paragraph 1 of Article 19 (Students and Trainees) is not mentioned here, that qualification is implicit. The Indonesian requirement that graduates of private universities pass a state examination does not imply that such universities are not recognized; such universities are meant to be covered by this Article. However, the Article is meant to apply to academic or technical programs only, and not to recreational courses. This exemption is available only once to any given individual. Thus, for example, an individual

who spends one or two years teaching in the United States, leaves for a year, and then accepts a teaching or research position at another U.S. university may not claim the exemption during the second visit if he has claimed an exemption under this Article during the first visit. An individual who stays longer than two years will be exempt for the first two years from the date of arrival and will be taxable thereafter.

The exemption provided in this Article with respect to research activities is not available if the research is undertaken primarily for private benefit. Thus, for example, income earned while performing research on cancer for which the rights to any discoveries are owned by a particular drug firm would not qualify, even though the research itself is of public interest.