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V5451-26 6 August 2026 · SG de Fiscalidad Internacional Criterion in force
IRPF · residencia fiscal

Tax exemption for the European University Institute does not apply automatically to fellows

A researcher inquires whether their postdoctoral fellowship in Italy is exempt under the European University Institute Convention and if they will be considered a tax resident in Spain. The DGT rules that, as it has not been proven that the researcher belongs to the categories of personnel entitled to privileges, the fellowship does not benefit from this specific exemption, and their residency will depend on criteria regarding duration of stay and centre of economic interests.

The question raised

The taxpayer asks whether they would be a tax resident in Spain and the taxation of the income corresponding to the scholarship, specifically, whether it would be exempt under the Convention establishing a European University Institute.

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