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A Spanish producer asked whether a services contract with a US company qualifies the production as foreign. The DGTC states it is not competent to classify the production but explains the conditions for applying the deduction under article 36.2 of the Corporate Income Tax Act.
Cuestión planteada 1. Confirmación de que la producción descrita se ha de calificar como extranjera.
La Administración no tiene competencia para determinar si una producción específica es extranjera. No obstante, si la producción fuera calificada como extranjera, los productores registrados que realicen la producción ejecutiva podrán aplicar la deducción del artículo 36.2 de la LIS, siempre que cumplan los requisitos y límites establecidos en dicha norma.
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