In-kind Contributions: Taxation of International Consortium Workers

Research output: Contribution to journalArticlepeer-review


In 2009, consistent with its objective to support and develop a European research infrastructure, the European Union (EU) created a new
organizational form for research collaborations: the European Research Infrastructure Consortium (ERIC). Since then, 21 different ERICs have
been established in the EU Member States; the largest being the European Spallation Source (ESS).

The financing of this ERIC is dependent on in-kind contributions of goods and labour from the various Member States of the ERIC. This
model of financing the ERIC instigates questions about which state has the right to tax that labour.

In terms of taxation of the workforce, the ERIC is different compared to EU institutions or international research organizations such as the
European Organization for Nuclear Research (CERN) for which taxes are levied at an organizational level rather than at a state level. This
entails that the taxation of the workforce of the ERIC becomes more complex as the allocation of taxing rights on a state level is dependent of the
applicable tax treaties entered into between the host states of the ERIC and Member States that are contributing towards the construction of the

Accordingly, the income from the work performed by the personnel may fall both within the scope of Article 15 as well as Article 19 of the
OECD Model Tax Convention.
Original languageEnglish
Pages (from-to)422-434
Number of pages13
Issue number5
Publication statusPublished - 2021 Apr

Subject classification (UKÄ)

  • Law (excluding Law and Society)

Free keywords

  • European research infrastructure consortium ERIC
  • European Spallation Source (ESS)
  • European Organization for Nuclear Research (CERN)
  • OECD
  • Article 15
  • Article 19
  • public legal entities
  • government service
  • income from employment
  • in-kind contribution
  • international taxation
  • tax


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