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V1531-14 11 June 2014 · SG de Fiscalidad Internacional Criterion in force
IRPF · investigación

Greece research income may be tax-exempt under treaty conditions

A Spanish resident researcher asks whether income from a Greek research centre is tax-exempt. The DGT states that under the Spanish-Greek Double Taxation Agreement, such income is not taxable in Greece if the research is of public interest and lasts no more than two years.

The question raised

Application of Article 20, relating to professors and researchers, of the Spanish-Greek Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on wealth.

The DGT's ruling

Remuneration for research in higher education institutions in Greece is exempt from taxation in that State if the activity is carried out in the public interest and for a maximum period of two years. This provision does not determine tax residence, which shall be established according to the legislation of each State and Article 4 of the Convention. The taxpayer shall be a resident in Spain if the circumstances of Article 9 of Law 35/2006 are met.

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