It may be right, but the exemption has to come from somewhere, and the place to look is the professors-and-teachers article of the treaty between the two countries. Not every treaty has one, the wording varies, and the conditions usually cover what the appointment is for, who the host institution is, and how long the exemption runs from arrival. A payroll office applying a rule of thumb is not the same thing as an article that applies to your facts. Ask which treaty and which article, then read it against your contract before relying on the exemption.
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Many treaties contain a professors-and-teachers article that exempts remuneration for a limited period from arrival — and the period does not restart for a second appointment in the same country. A provision that applies to this occupation and not the one beside it is what changes the answer.
The rule for this group
Many treaties contain a professors-and-teachers article that exempts remuneration for a limited period from arrival — and the period does not restart for a second appointment in the same country.

The carve-out
My university says my first two years are exempt and cannot cite the article.
Your next step
The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on Cross-border tax for professors & lecturers. If you already have an adviser, we will tell you what they should be asking rather than replacing them.
Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
Cross-border tax case studies
Finding the article behind a university's exemption promise
A newly appointed lecturer had been told by the host institution's payroll office that the early years of salary were exempt, with no article cited. We identified the treaty in force between the two countries, read the professors-and-teachers article against the appointment letter, and confirmed what it covered and from when. The engagement produced a written note of the article, its conditions and the period it runs for, a return in the home country claiming relief on that basis, and a diary entry for the date the exemption ends so payroll can be corrected before it does.
Read how this one runsA further appointment where the exemption had already been used
A professor returned to a country where an earlier post had been covered by the treaty relief, and the new department assumed the exemption applied again. It did not, because the period runs from arrival and does not restart. We established what had been claimed on the earlier engagement, advised that the new remuneration was taxable from the outset, and put the payroll on the correct footing before the first payment. The work produced a documented history of the earlier claim, correct withholding from the start, and no arrears to settle at the end of the year.
Read how this one runsSeparating grant funding from teaching remuneration
A researcher's return reported a university salary and nothing else, although funding was arriving from bodies in several countries. Some of it was payment for work done, some reimbursed laboratory costs, and some belonged to the institution rather than the researcher. We read each funding agreement, characterised the streams, sourced them and reported them accordingly. The engagement produced a schedule of every award with its character and its country, corrected returns covering the streams that had been omitted, and relief claimed only where a treaty article genuinely reached the income.
Read how this one runsA sabbatical that did not break residence, evidenced at the time
An academic spent a year abroad on sabbatical and both countries had a claim to residence, which the file had resolved by assumption rather than analysis. We gathered the facts while they could still be obtained: the retained family home, the post held open, the contractual return date, the pattern of visits. The engagement produced a residence position with the supporting evidence attached, a treaty tie-breaker analysis for the period when both domestic tests pointed to residence, and a filing pattern in both countries consistent with that single position for the year in question.
Read how this one runsExternal examining fees reported as employment income
A lecturer's external examining and paid lecture work for institutions in another country had been folded into the employment figure on the return, so the wrong treaty article was applied and the exemption claimed did not fit the income. We characterised each engagement separately, distinguishing the contracted post from the professional fees, and re-filed. The work produced a corrected return in which the salary and the fees are reported under their own rules, withholding put right at source for the fee engagements, and a note setting out the distinction for later years.
Read how this one runsExemption period ending mid-contract and payroll set for it
A visiting professor's relief was due to expire part-way through a long appointment, and nothing in the payroll arrangement anticipated it. Left alone, it would have produced a substantial underpayment at the end of the year in which the period closed. We calendared the end date from the date of arrival, notified the institution, and arranged for withholding to begin from that point. The engagement produced a dated schedule of the relief period, an instruction to payroll with the change built in, and a home-country filing plan for the years either side of the switch.
Read how this one runsA Canadian Employer With Staff in the United States
Employing someone in the US creates federal and state obligations that begin with registration, not with the first return. Which states are engaged is decided by where the work happens rather than where the company is.
Read how this one runsIndian Rent Collected While Resident Somewhere Else
Rent from Indian property is taxed in India and again where you live, with relief on one side only. The file gets the Indian deduction right first, then claims the credit on the home return against what was actually paid.
Read how this one runsAll case studies — every published engagement in one place.
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More on Professors & lecturers
Generally not. The relief is usually framed as a limited period running from the date of arrival, and a further appointment in the same country does not reset the clock. That catches people who left, spent time elsewhere and came back, either to the same institution or to a different one in the same country, assuming the exemption was available again. The practical consequence is that the later period is taxable from the start, with no payroll adjustment to soften it. Check what was claimed the first time before relying on it again, because the earlier claim is part of your record.
It depends on what the grant actually is. Some grants are remuneration for services in substance, some reimburse costs, and some are awards to the institution that merely pass through your hands. Each is treated differently, and a treaty article that might exempt teaching remuneration may not reach a grant at all. Where several funders in several countries are involved, each stream needs to be identified separately, with the funding agreement read rather than the covering letter. The common failure is a single return that reports the salary and is silent about everything else.
Often not, which surprises people who expected it to. Residency turns on where your settled life is, and a sabbatical with the family home kept, the post held open and a return date in the contract usually points to residence continuing throughout. A longer absence, with the home let out and the family moved, can point the other way. The country you spent the year in applies its own test at the same time, and both can answer yes, at which point the treaty tie-breaker decides. It is worth forming a view and documenting it while the facts are still fresh.
Usually yes. An exemption under a treaty article is relief from tax, not a release from reporting, and in most systems it has to be claimed on a return before it applies. Filing is also what puts the claim on the record, which matters later if the period or the conditions are ever questioned. If you remain resident in your home country, the salary generally goes into that return as well, with relief applied there. The two filings are what make the position visible in both places rather than assumed in one of them.
Both shapes exist in academic work, and the difference decides which treaty article you are even looking at. A visiting post with a contract, a department, set hours and a payslip is ordinarily employment. A series of paid lectures, external examining or consultancy for an institution can be a business activity instead. The relief available differs between the two, and so does responsibility for withholding. Establish the character of each engagement before considering any exemption, because an article written for teaching remuneration does not necessarily cover fees for professional services.
You claim relief once, in the right country, in the right order. Usually the source country taxes first, the residence country then gives a credit for that tax against its own charge on the same income, and a treaty caps the source-country rate. Getting the order wrong is what produces a double charge you then have to unwind. The mechanism differs by income type, which is why we map the whole position before filing either return. See how to avoid double taxation.
It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.



