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V0373-22 25 February 2022 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Foreign private entity research scholarships not tax-exempt without specific requirements

A researcher asks whether a postdoctoral fellowship from a Finnish foundation is tax-exempt in Spain. The DGT rules that, as it is from a private foreign entity and does not meet the exemption criteria for regulated studies or specific research, the fellowship constitutes taxable income from work.

The question raised

Question posed: Whether the scholarship is taxable in Spain and, if so, the tax treatment.

The DGT's ruling

Scholarships constitute earned income pursuant to Article 17 of the Personal Income Tax Act (LIRPF). For a research scholarship to be exempt under Article 7.j), it must meet specific requirements, such as being registered in the corresponding registry or the status of civil servant or researcher being an express requirement in the call for applications. In this case, the scholarship from a foreign private foundation does not fall within the exemptions for formal studies or those for research described in the regulations.

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