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V0281-24 4 March 2024 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · exención

Medical research grants are not exempt from Personal Income Tax if they fail to meet LIRPF requirements

A foundation has requested clarification on whether medical research project grants are exempt from Personal Income Tax (IRPF) under Article 7 j). The Directorate General for Taxes (DGT) has ruled that they are not exempt, as they do not pertain to formal studies, do not fall within the scope of the Statute for Researchers in Training, and do not require the recipient to hold a civil servant or teaching position as a condition of the call.

The question raised

1.- Whether the exemption regulated in Article 7 j) of the Personal Income Tax Law is applicable to the amounts received by the beneficiaries of said grants.

The DGT's ruling

The grants do not benefit from the exemption provided in Article 7 j) of the Personal Income Tax Law (LIRPF) as they are not for regulated studies nor do they fall within the scope of Royal Decree 63/2006. Furthermore, the exemption for civil servant researchers does not apply if such status is not an express requirement or merit in the terms and conditions. These amounts are taxed as employment income and cannot be reduced by the expenses incurred by the beneficiary.

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