How the DGT's position has evolved
Current position
The deduction base includes expenses for creative personnel residing in Spain or the EEA and technical industries carried out in Spanish territory. Creative personnel expenses are subject to a limit of 100,000 euros per person throughout the entire production. In the case of services partially provided in Spain, only the portion corresponding to the service performed in said territory is included in the base.
The DGT's position remains constant in the definition of deductible concepts, focusing the base on creative personnel and technical industries. The only relevant change is the increase in the limit per person belonging to the creative personnel, which rises from 50,000 to 100,000 euros according to ruling V2844-21.
Turning points
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Increases the deduction limit for creative personnel from 50,000 to 100,000 euros per person throughout the entire production.
Analysis based on 8 of 9 rulings with a stated position. Updated 29 September 2026.