US/UK tax treaty - classification of research grant

I am a US citizen residing in the UK. I moved to the UK on 25 April 2024 to work as a university lecturer, but I still maintain a permanent home in the USA where my family resides. Between 1 May 2024 and 3 April 2025, I received payments made directly to me from the US federal government as part of a research grant. The grant requires me to work on a specific project and file reports as conditions of receiving the money. I worked on the project in the US, UK and a third country, but primarily in the UK. All of the payments were made and remained in the USA. I have already paid tax on the grant amount to the USA. My question is: Would this grant be considered payment for government service as described in the US/UK tax treaty article 19.1? If this is the case, then I am only liable for tax on it to the UK (not the USA) because I meet the conditions in 19.1.b.

Hi ,
 

Its more likely to be article 20(a)  . Thank you .

Thank you. I see in Article 20A that the exemption is valid for only two years. My employment contract is for 5 years. Does this mean i can take the exemption for years 1 and 2 but not years 3-5?

Hi,
That is correct.
Thank you

I appreciate that information. Just one final question. Would the type of visa that I hold be important to determining whether the payment is covered under 20?

Hi AES
No
Thank you.