Re: PAYE Exclusion Orders and Double taxation treaty between Ireland & India

I have a question related to tax residence, and specifically regarding PAYE exclusion orders based upon the double taxation treaty between Ireland and India. A couple of relevant links:

Revenue info: https://www.revenue.ie/en/jobs-and-pensions/tax-residence/paye-exclusion-order.aspx

The Ireland-India double taxation treaty: https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/i/india.pdf

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I have an India colleague who has been working with me at a chemistry research company in Dublin for almost two years now. When he started working he applied to revenue for a PAYE exclusion order which resulted in him effectively not paying taxes on his income.

I know from page 31 of the treaty linked above that he (a full-time Research Scholar) "shall be exempt from tax in that other State <Ireland> on any remuneration for such teaching or research for a period not exceeding two years from the date of his first arrival in that other State for such purpose "

It would therefore appear that the exclusion order will terminate after two years. (correct me if this is not true)

What I am wondering is:

- If the the exclusion terminates, what will happen if he continues to work in Ireland? Will he simply start seeing PAYE being taken on his payslip like any other ordinary "resident"? Or (the burning question) would Revenue seek to retrospectively recoup the taxes waived under the period of the exclusion order?

- Is he really earning income "tax free", or is it really the case that he has tax obligations to meet in India? e.g. India sees him as working abroad temporarily and he is expected to continue paying his income tax to the Indian Govt. while working from Ireland?

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Thanks in advance!! Also if this post would be more relevant in another sub reddit please let me know.

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