How the DGT's position has evolved
Current position
Financiers of audiovisual productions may apply the deduction under Article 36.1 of the LIS (Corporate Income Tax Law) by multiplying their contributions by 1.20. To do so, they must provide funds for production costs without acquiring intellectual property rights and must communicate the contract and the certification to the Administration before the end of the tax period. The financier's deduction cannot exceed the deduction generated by the producer.
The DGT's position has shifted from focusing on the accounting treatment of the contribution as a grant (V1736-22) to precisely defining the operational requirements for third parties to use the deduction. Subsequent rulings have clarified quantitative limits, the necessity of contracts, and the financier's liability in the event of the producer's failure to comply with permanence requirements.
Turning points
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Establishes that the financier may apply the portion of the deduction corresponding to them in proportion to their contribution, subject to the limits of the LIS.
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Specifies that the deduction is limited to 120% of the amounts contributed and requires the communication of the contract and certification to the Administration before the end of the tax period.
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Introduces the financier's liability to regularize the deduction if the producer fails to comply with the permanence requirement of the work.
Analysis based on 12 of 12 rulings with a stated position. Updated 27 September 2026.