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V2402-15 29 July 2015 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · deducción por inversiones

Canary deduction rate for foreign audiovisual productions reaches 35%

A Canary entity inquires whether the deduction rate for foreign audiovisual productions is raised to 35% due to its fiscal residency. The DGT confirms that, under Canary regulations, the rate exceeds the general regime and reaches this level.

The question raised

Question raised 1. Whether the deduction rate provided for in Article 36.2 of the LIS is increased to 35% for entities with tax residence in the Canary Islands.

The DGT's ruling

For entities with tax residence in the Canary Islands, the deduction percentage for foreign audiovisual productions is 35%, as it is 80% higher than the common regime (15%) with a minimum differential of 20 points. The deduction limit for expenses incurred in the Canary Islands is 4.5 million euros. The deduction base includes creative personnel expenses (with residence in Spain or the EEA) and technical industries, but excludes general administrative, distribution, exploitation, or financial expenses.

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