Doctrine by topic · DGT Observatory

Competitive Bidding: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

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How the DGT's position has evolved

Settled doctrine High confidence 8 rulings · 2016–2023

Current position

Scholarships for regulated studies leading to an official degree are exempt according to article 7.j) of the LIRPF (Personal Income Tax Law). To qualify, the aid must require enrollment in said studies and comply with requirements regarding publicity and a competitive bidding process. If the aid does not require enrollment as a condition, it is taxed as employment income.

The DGT's position remains constant in requiring competitive bidding and the purpose of regulated studies for the exemption. The rulings confirm that the absence of a direct link to enrollment or the lack of a public nature of the call strips the aid of its exemption, classifying it as employment income.

Analysis based on 8 of 8 rulings with a stated position. Updated 2 October 2026.

Rulings on this topic

8

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