Ruling No. 187/2026 recognises the favourable tax treatment of Erasmus Mundus Joint Master scholarships. From 2027, the exemption rule will be moved to Article 222(5) of the new Consolidated Income Tax Code.
The case examined by the Italian Revenue Agency
In Ruling No. 187 of 23 October 2026, the Italian Revenue Agency (Agenzia delle Entrate) addressed the tax treatment of Erasmus Mundus Joint Master (EMJM) scholarships, awarded under international master’s programmes run by consortia of Italian and foreign universities.
A student enrolled for the 2025/2026 academic year in a two-year programme had been awarded a scholarship of EUR 1,400 per month for 24 months, EUR 33,600 in total. However, the coordinating university had applied IRPEF withholding, paying a net monthly amount of EUR 1,238. The taxpayer therefore asked whether the scholarship could fall within the exemption provided for the Erasmus+ programme.
The tax treatment of scholarships
As a general rule, Article 50(1)(c) of Presidential Decree No. 917/1986 (TUIR) classifies amounts paid as scholarships and other forms of support for study or training purposes as income treated as employment income, where the beneficiary has no employment relationship with the paying entity. As a result, scholarships received by taxpayers who are tax resident in Italy are taxable, unless a specific exemption applies.
For Erasmus+ international mobility scholarships, Article 1(50) of Law No. 208/2015 refers to the exemptions in Article 1(3) of Decree-Law No. 105/2003. Circular No. 20/E of 18 May 2016 clarified that the measure entails IRPEF exemption for the beneficiary students and IRAP exemption for the paying bodies.
Why Erasmus Mundus falls within Erasmus+
Regulation (EU) 2021/817 established the Erasmus+ programme for 2021–2027 in continuity with the previous programming period and expressly includes Erasmus Mundus joint master’s degrees among the supported actions.
The European Education and Culture Executive Agency (EACEA) has also confirmed that Erasmus Mundus is an Erasmus+ action and that EMJM scholarships are one of the forms of funding provided for by the European programme.
The Italian Revenue Agency therefore concluded that the EMJM scholarship at issue is exempt from IRPEF because it is paid under Erasmus+. The clarification concerns the tax treatment of this specific type of scholarship and does not, on its own, amount to a blanket exemption for any scholarship linked to an international programme.
From 1 January 2027: the references in the new Consolidated Code
Legislative Decree No. 117 of 19 June 2026 has reorganised the rules on income taxes. Although the decree entered into force on 4 July 2026, Article 377 provides that it applies from 1 January 2027. For 2026, the legal references used in the ruling therefore remain relevant.
- The general rule in Article 50(1)(c) of Presidential Decree No. 917/1986 is reproduced in Article 52(1)(c) of Legislative Decree No. 117/2026.
- The Erasmus+ exemption in Article 1(50) of Law No. 208/2015 is transposed into Article 222(5) of the new Consolidated Code.
- The reference to Article 1(3) of Decree-Law No. 105/2003 is found, from 2027, in Article 215(1), expressly referred to by the new Article 222(5).
Practical implications for students and universities
For students and the universities responsible for payment, it is important to correctly identify the funding programme and to verify the requirements for applying the exemption. If withholding was applied to scholarships falling under the same rules, it will be advisable to check the tax certification and to assess, in practice, how any amounts withheld in excess can be recovered: the ruling does not set out a specific refund procedure.