How the DGT's position has evolved
Current position
AIEs maintain their special tax regime as long as they effectively carry out the activities of their corporate purpose, regardless of the activity of their members. The deduction applies if the entity assumes the risk and venture of production or exhibition. In cases of third-party financing, the financier may apply the deduction with a limit of 1.20 times their contribution, without exceeding the deduction generated by the producer.
The DGT's position remains constant regarding the independence of the members' activity from the AIE regime. Throughout the rulings, the scope of the deduction base has been specified and the treatment of third-party financing has been clarified. No changes in criterion are observed, but rather a consolidation of the application of the special regime.
Turning points
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Establishes that for the application of the deduction, it is not necessary for the members to carry out cinematographic activities, provided that the AIE holds the ownership of the rights.
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Specifies the treatment of third-party financing, allowing the financier to apply the deduction with a limit of 1.20 times their contribution.
Analysis based on 48 of 52 rulings with a stated position. Updated 19 September 2026.