How the DGT's position has evolved
Current position
Taxpayers who finance production costs without acquiring intellectual property rights may apply the deduction under article 36.1 LIS (Corporate Income Tax Law), limited to 120% of the amounts contributed. To do so, it is necessary to enter into a financing contract and submit the certification of requirements to the Administration. In the case of live performances, the base is determined by direct costs minus subsidies and transfers received.
The DGT's position remains constant at the core of the incentive, confirming the 120% limit on contributions and the need for a contract and certification. Clarifications have been added regarding the deduction base for live performances and the extension of the benefit to IRPF (Personal Income Tax) taxpayers with economic activity. No fundamental changes are observed, but rather a consolidation of the operational requirements.
Turning points
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Establishes the deduction limit by multiplying the amounts contributed by 1.20 and requires the absence of a link between the financier and the producer.
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Introduces the responsibility of the financier to regularize the deduction if the producer fails to meet the requirement regarding the permanence of the work.
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Clarifies that the incentive is applicable to IRPF taxpayers carrying out economic activities with the same percentages and limits.
Analysis based on 8 of 8 rulings with a stated position. Updated 13 November 2026.