Doctrine by topic · DGT Observatory

Predoctoral Contract: 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 · 2018–2026

Current position

Amounts received through an employment contract are not considered scholarships and must be taxed as income from employment. For a research scholarship to be exempt, it must comply with the requirements of Royal Decree 63/2006 and there must be no employment relationship. The exemption for teaching or research staff only applies if the call for applications requires such status as an express requirement or merit.

The DGT's position has remained constant since 2018, reaffirming that the existence of an employment contract is incompatible with the nature of a scholarship. Throughout the rulings, it has been reiterated that the exemption under article 7.j) of the Personal Income Tax Law (IRPF) does not apply to predoctoral contracts, and it has been specified that the call for applications must require researcher status to apply other exemptions.

Turning points

  1. V3336-19

    Clarifies that the exemption for work performed for non-resident entities is not applicable to remuneration during leave or mobility periods in predoctoral contracts.

Analysis based on 8 of 8 rulings with a stated position. Updated 1 October 2026.

Rulings on this topic

8
V0909-26 24 Apr 2026

Income from predoctoral researcher contracts is not exempt from tuition

SG de Impuestos sobre la Renta de las Personas Físicas
rendimientos del trabajobecas exentascontrato predoctoralinvestigador en formaciónexención de becas LIRPF — Ley 35/2006 del IRPF art. 7.jLIRPF — Ley 35/2006 del IRPF art. 17.1
Affects CompanyExpat · Non-residentIndividual

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