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V2605-25 23 December 2025 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · sociedad civil

Film financing income included in taxable base upon accounting accrual

A civil society inquired about the tax treatment of funds received from investors for film production. The DGT responds that such income must be charged to the period in which it accrues accounting-wise, in accordance with the General Accounting Plan.

The question raised

Yes, given that the film may take some time to begin filming and consequently to generate profits, and insofar as the income that the consulting entity is going to receive would, in principle, remain immobilized in the assigned bank account, what is the applicable treatment in Corporate Income Tax.

The DGT's ruling

The amounts received by the producer as financing must be recorded as income in accordance with the applicable accounting regulations. Pursuant to Articles 10.3 and 11.1 of the LIS, the tax treatment shall be the same as the accounting treatment, being included in the tax base in the fiscal year in which they have accrued. The allocation shall depend on the purpose of the subsidy or financing, in accordance with the 18th accounting standard of the PGC.

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