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A query was raised regarding whether an Economic Interest Grouping (AIE) can be considered a producer for film production tax credits without possessing its own resources. The Directorate General for Tax (DGT) ruled that it can, provided it meets the requirements of an independent producer and the tax credit is allocated to its members.
Question posed 1. Whether the AIE will hold the status of producer for the purposes of Article 36.1 of the LIS, given that there are no requirements regarding minimum material or human resources at the AIE's headquarters, and the AIE may subcontract 100% of its activity. And whether the AIE will be entitled to the aforementioned deduction.
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