How the DGT's position has evolved
Current position
The deduction base includes the costs of creative personnel (resident in Spain or the EEA) and technical industries carried out in Spanish territory. Creative personnel costs are limited to 100,000 euros per person throughout the entire production. In the case of services partially provided in Spain, only the portion corresponding to the activity carried out in national territory is included.
The DGT's position remains constant in the definition of the concepts of technical industries and creative personnel. The only relevant change is the increase in the deduction limit for creative personnel, which rises from 50,000 to 100,000 euros per person according to ruling V2844-21.
Turning points
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Raises the deduction limit for creative personnel to 100,000 euros per person, clarifying that this amount applies throughout the entire production.
Analysis based on 8 of 10 rulings with a stated position. Updated 29 September 2026.