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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 20

Teacher, Students and Other Persons in Training

(1) Remuneration derived by a professor or teacher who is or has been a resident of a Contracting State immediately prior to transferring to the other Contracting State for a maximum period of two years for the purpose of undertaking advanced studies, research or teaching at a university, higher education school, school or other educational institution, shall not be taxable in the other Contracting State provided that the remuneration does not arise in the last-mentioned State.

(2) An individuals who is or has been a resident of a Contracting State immediately prior to visiting the other Contracting State, and remains temporarily in that other State solely as a student at a university, higher education school, school or other similar educational institution of the other State, or as an apprentice (including "Volontar" or "Praktikant" in the Federal Republic of Germany), such person shall be exempt from tax by the other State from his arrival in the other State, and in connection with his stay:

  • (a) for all transfers from abroad, intended for his maintenance, education or training; and
  • (b) for a total period of three years for all remuneration for works performed in the other Contracting State to complete his resources available to him for such purposes, up to a tax year total of 8,400 DM or the equivalent thereof in Ecuadoran currency.

(3) An individual who is or has been a resident of a Contracting State immediately prior to transferring to the other State, and temporarily remains in the other Contracting State solely for purposes of studies, research, training, or as the beneficiary of a subsidy, allowance or scholarship from a scientific, teaching, religious or charitable organization, or in the framework of a technical assistance program undertaken by the Government of a Contracting State, shall not be taxed in that other State from his first day of arrival therein, and in connection with his visit:

  • (a) for the amount of such subsidy, allowance or scholarship;
  • (b) for all transfers from abroad, intended for his maintenance, education or training.