How the DGT's position has evolved
Current position
The deduction for production expenses allows for the inclusion of creative personnel, technical industries, music rights, technical services, set design, filming, and post-production carried out in Spanish territory. For creative personnel, there is a limit of 100,000 euros per person throughout the entire production. In the Canary Islands, increased rates and limits of 80% apply, provided that the expenses are effectively incurred in the archipelago. The partners of an AIE (Film Investment Company) apply the imputed deduction bases in their own tax returns.
The DGT's position remains stable regarding the definition of deductible concepts and the exclusion of general expenses. An evolution in technical precision is observed, such as the increase in the per-person limit from 50,000 to 100,000 euros and the clarification that this amount applies to the production as a whole. The doctrine confirms the application of Canary Islands incentives, strictly conditioned on the location of the expenses.
Turning points
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Raises the deduction limit for creative personnel to 100,000 euros per person and clarifies that this amount is calculated based on the production as a whole.
Analysis based on 8 of 8 rulings with a stated position. Updated 13 October 2026.