Skip to content In Ruling No. 53/2026, the Italian Revenue Agency addresses the issue of the tax treatment applicable to scholarships granted to foreign postdoctoral researchers within projects funded by the European Union. The ruling stems from an advance tax ruling request submitted by an Italian university acting as coordinator of the ALFA project, part of the Horizon Europe programme, under the Marie Skłodowska-Curie Staff Exchanges actions. The project aims to promote academic mobility and scientific exchange between European and Latin American institutions through periods of secondment.
Factual background and the question raised
The requesting university provides scholarships referred to as “visiting research” grants, financed directly with the EU funds allocated to the project. These amounts, ranging from EUR 2,300 to EUR 4,600 for a thirty-day stay, are intended to cover the researchers’ travel, transportation, board, and accommodation expenses.
The beneficiaries are postdoctoral researchers employed by partner universities located outside the European Union, who carry out research activities at the Italian university without establishing any employment relationship with it.
The question submitted to the tax authorities concerns whether these payments may benefit from an exemption from Italian personal income tax (IRPEF). The applicant university argued for such treatment based on an analogy with EU mobility programmes such as Erasmus+ and by invoking Article 3(3)(d-ter) of the Italian Consolidated Income Tax Act (TUIR), which excludes from the taxable base scholarships granted by the Italian Government to foreign citizens pursuant to international agreements.
Exemption regimes and recent legislative developments
The Revenue Agency first classifies the amounts at issue as income assimilated to employment income pursuant to Article 50(1)(c) of the TUIR, as they are granted for the purposes of scientific research and in the absence of any relationship of subordination with the paying entity.
With regard to non-resident individuals, Article 23(2) of the TUIR provides that such income is deemed to be sourced in Italy when paid by an Italian resident entity, with the consequence that it is taxable in Italy.
Having clarified the income nature of the payments, the tax authorities then assess whether they fall within any of the specific statutory exemptions provided for under Italian law. Such derogations are limited to explicitly identified cases, including regional or provincial scholarships, PhD scholarships, Erasmus+ mobility allowances, and government scholarships granted to foreign citizens pursuant to international agreements.
Particular relevance is given to the reform introduced by Decree-Law No. 45 of 2025, which significantly amended the legal framework governing university scholarships. The reform abolished the tax exemption previously applicable to post-graduate research scholarships and, at the same time, introduced into Law No. 240 of 2010 new contractual instruments, namely postdoctoral appointments (“incarichi postdoc”) and research appointments (“incarichi di ricerca”).
In light of this legislative reform, postdoctoral research activities may no longer be financed through tax-exempt scholarships, but must instead, where appropriate, be carried out under the newly regulated contractual arrangements introduced by the legislature.
The principle of strict interpretation of tax relief provisions
A central element of the Agency’s reasoning is the principle of strict interpretation of tax relief provisions, repeatedly affirmed by the Italian Supreme Court.
On this basis, the Revenue Agency excludes the possibility of extending by analogy the preferential tax regime applicable to Erasmus+ mobility allowances to different programmes, even if they pursue similar objectives of international mobility.
Accordingly, the Agency denies the applicability of Article 3(3)(d-ter) of the TUIR, since the payments are not granted directly by the Italian Government, but rather by a university, albeit within a project financed by the European Union.
As a result, the Agency concludes that the “visiting research” scholarships must be subject to taxation under Article 50 of the TUIR. Consequently, the university, acting as a withholding agent, is required to apply the withholding tax provided for by Article 24 of Presidential Decree No. 600 of 1973, while also granting the applicable tax deductions.
Concluding remarks
Ruling No. 53/2026 aligns with the new regulatory framework established by the legislature, marking the definitive abandonment of the possibility of using scholarships as a tax-favoured instrument for postdoctoral research activities.
The approach adopted appears consistent with the principle of specificity of tax exemptions and with the need to avoid extensive interpretations in the field of tax reliefs.
Nevertheless, the proposed solution raises certain systemic and operational issues, particularly with regard to the ability of Italian universities to attract foreign researchers within European mobility programmes.