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An Economic Interest Group (AIE) inquired whether hiring Spanish actors and technicians assigned to a Spanish centre allows their costs to be treated as incurred in Spain for film production tax credits, even if the filming takes place abroad. The Directorate General for Taxes (DGT) ruled that only the portion of the service actually performed within Spanish territory counts as an expense in Spain.
This ruling limits the scope of film production tax credits by strictly applying the territoriality principle to service costs, preventing the inclusion of foreign-based filming expenses even when the personnel are Spanish-based.
The tax team reviews your specific situation.
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