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HMRC internal manual

Film Production Company Manual

Co-productions: the film production company

CTA2009/S1182

The film tax regime treats qualifying co-productions differently from other films in one respect. The conditions which a company must meet to be treated as a film production company (FPC)(FPC10110) for a co-production are relaxed.

The UK co-producer is not required to meet all the conditions listed at FPC10110 but is instead only required to make an effective creative, technical and artistic contribution to the film.

This reflects the fact that the activities that normally characterise an FPC will, in the case of a co-production, by definition be shared between two or more companies, so there may be no single company in the position to meet all elements of the definition.

This special rule for companies making co-productions does not apply in the case of films made outside the terms of the UK’s official co-production agreements. In such cases, a UK co-producer can only qualify for FTR by meeting in full the requirements for a film production company set out in FPC10110.