Is my postdoc fellowship taxed as salary or as a grant?
Characterisation is decided by what the money is for, not by the word printed on the payment advice. A fellowship or grant paid to support your own research and training is treated differently from wages paid for work performed for an employer, and the two fall under different rules in most systems. The difficulty is that a university payroll department has one process and runs a stipend through it as employment income because that is the process it has. Ask the institution which characterisation it applied and on what basis, then check that against the article your own treaty uses. Where the two disagree, the fix is a documented position rather than a phone call.
When does the student and trainee treaty exemption clock start?
From your arrival in the host country, under most treaties, rather than from the date the grant begins or the date you were first paid. That distinction decides more disputed cases than any other feature of these articles. Researchers routinely arrive on one status, spend a period unpaid or on a different funding line, and only then start the fellowship — by which point part of the exemption period has already run. Work the start date out from immigration and travel records before you rely on the exemption, and keep those records. The clock is a question of fact, and the fact has to be provable.
My postdoc exemption ran out mid-contract, what now?
Nothing in these articles stops an exemption expiring in the middle of an engagement, and when it does the same stipend becomes taxable where the work is done from that point on. The usual mistake is to treat the year as a single unit. It is not: the year splits, part of the income falls inside the exemption and part does not, and the withholding almost never adjusts itself. Expect to compute the split, reconcile what was actually withheld against what was due, and claim credit at home for the taxed portion only.
Do days spent on a research visa count towards residency?
They count unless something is filed to exclude them, and in our experience that filing is routinely missed by academic arrivals. Many systems allow certain days present under a study or training status to be left out of the residency day count, but the exclusion is not automatic. It is claimed, on a statement, for the year in question. Researchers who never made the claim are often assessed as resident for the very years they believed themselves exempt. If nobody has ever filed it on your behalf, assume it has not been filed.
I moved between universities in two countries, who taxes what?
Each engagement is looked at separately. Income is sourced to the place the work was physically done, so a year split across institutions in different countries produces two sourcing positions, two possible exemption claims, and one home return that has to reconcile both. The travel record is the evidence for the split, and it needs to be a record rather than a reconstruction. Build it from boarding passes, entry stamps, tenancy dates and contract dates while they are still to hand, because the alternative is asserting a split you cannot support.
Does my home country still want a return while I am on a fellowship abroad?
Usually yes, for as long as you remain resident there, and being exempt from tax in the host country does nothing to remove that obligation. The two questions are separate: whether the host country may tax the fellowship, and whether your home country still requires you to report it. Academics on a run of short contracts often remain resident at home throughout, and the returns nobody filed accumulate quietly. Filing them before anyone asks is a materially better position than filing them afterwards.
What is double taxation?
Double taxation means the same income being taxed by two authorities. It comes in two forms: juridical, where two countries each tax one person on one amount, and economic, where two different people are taxed on the same underlying profit — a company on its earnings and a shareholder on the dividend paid out of them. Relief comes from a treaty, a foreign tax credit, or an exemption, and which one applies depends on the income type. How to avoid double taxation sets out the routes.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
