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V2458-23 14 September 2023 · SG de Impuestos sobre la Renta de las Personas Físicas Criterion in force
IRPF · rendimientos del trabajo

Pre-doctoral contract remuneration is not exempt from Personal Income Tax (IRPF)

A trainee researcher enquired whether the remuneration from a pre-doctoral contract was exempt from Personal Income Tax (IRPF) on the basis of being a scholarship. The Directorate General for Taxes (DGT) ruled that it is not exempt, as payments under an employment contract are not considered scholarships, and the requirements for exemptions related to research or formal studies are not met.

The question raised

Whether the remuneration derived from said contract is exempt from taxation through the application of the Personal Income Tax Law.

The DGT's ruling

Amounts paid within the framework of an employment contract are not considered a scholarship. In this case, the aid is not included within the scope of Royal Decree 63/2006 for research, nor does it constitute a scholarship for pursuing formal studies. Furthermore, the exemption for university researchers is not met because the call for applications does not provide for the status of teacher or researcher as an express requirement or merit for the award.

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