How the DGT's position has evolved
Current position
The deduction for film productions applies to the entity with the status of producer, allowing AIEs (Audiovisual Investment Companies) to subcontract their activity without their own resources, provided they hold the ownership of the rights and the responsibility for the work. In the case of audiovisual series, the amount of the deduction and its limit are calculated per episode, but territorialization and the aid limit are computed based on the total cost of the season if it is contracted independently. Resident partners in Spain impute the deduction bases according to the economic rights they hold at the close of the period.
The DGT's position remains constant regarding the capacity of AIEs to act as producers and the imputation of deductions to their partners. The evolution is manifested in the technical precision regarding the management of audiovisual series, where a differentiated treatment is established between the calculation of the deduction per episode and the limits for aid and territorialization per season. The criterion has been consolidating regarding the requirements for the AIE as an independent producer.
Turning points
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It is specified that the AIE may subcontract its entire activity without the need for its own material or personal resources, provided it designates an executive producer and is an independent producer.
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Introduces the distinction for audiovisual series: the amount of the deduction is determined per episode, but territorialization and the aid limit are computed based on the total cost of the contracted season.
Analysis based on 27 of 28 rulings with a stated position. Updated 24 September 2026.