How the DGT's position has evolved
Current position
The basis for the deduction includes creative personnel expenses with residence in Spain or the EEA and technical industry or supplier expenses incurred in Spanish territory. In the case of services partially provided in Spain, only the portion corresponding to the service performed in said territory is included in the basis. The global budget for the limit set by Article 45 of the RIS must include both costs incurred in Spain and abroad.
The DGT's position remains constant in the definition of eligible expenses, focusing the basis on the territoriality of services and the residence of creative personnel. Clarifications have been introduced regarding the application of the deduction in specific contexts, such as the production of pilots, the management of balances due to insufficient tax liability, and the calculation of the global budget.
Turning points
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Establishes that for the purposes of the deduction, production must be understood as the complete season, provided it is contracted independently.
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Excludes COVID-19 sanitary prevention expenses from the deduction basis as they are not directly related to the production.
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Clarifies that the global budget for the limit set by Article 45 of the RIS must include both costs in Spanish territory and abroad.
Analysis based on 12 of 14 rulings with a stated position. Updated 26 September 2026.