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HMRC internal manual

Film Production Company Manual

HM Revenue & Customs
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Co-productions: more than one UK co-producer


There cannot be more than one film production company (FPC) in relation to a single film (FPC10110). This rule holds true in the case of co-productions as it does for other films.

In some cases, there may be more than one UK company involved in making a co-production under one of the international co-production agreements. In such circumstances, the company which is most directly engaged in making an effective creative, technical and artistic contribution to the film will be treated as the FPC for the film.

The company which is ‘most directly engaged’ will be a matter of fact, which will be determined on a case by case basis. The phrase ‘most directly engaged’ takes its everyday meaning.

In applying this rule, only the activities of the UK co-producers are taken into account. Where there is one co-producer in the UK and another overseas, the UK co-producer will be the FPC for the purposes of the Film Tax Relief, even where the overseas co-producer is more actively engaged in the production of the film as a whole.