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V2191-25 17 November 2025 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
ISD · subvención pública

Horizon-ERC Advanced Grants exempt from Inheritance and Gifts Tax

The consultant asks whether European research grants are subject to Inheritance and Gifts Tax. The DGT responds that such grants are not taxable as public subsidies for general public interest and do not constitute a civil donation.

The question raised

To determine whether taxation is required under Inheritance and Gift Tax (ISD) for the grant received.

The DGT's ruling

The receipt of the Horizon-ERC-ADG grant does not constitute a donation because the Administration does not act with the intent of liberality nor the will to enrich the beneficiary. As it is a public grant awarded to fulfill purposes of public or social interest, it is not subject to Inheritance and Gift Tax pursuant to Article 3.c) of the RISD. The text also analyzes the possible exemption from Personal Income Tax (IRPF) under the research scholarship requirements of Article 7.j) of the LIRPF.

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