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HMRC internal manual

Film Production Company Manual

Co-productions: attribution of expenditure between co-producers

A film production company’s (FPC’s) entitlement to Film Tax Relief (FTR) is based on the amount of core expenditure that it incurs (FPC50005).

Where the FPC was involved in a co-production HMRC would expect the arrangements between the co-producers to be such that each co-producer bore the expenditure for which they were ultimately responsible, and that the accounts of the FPC’s separate deemed trade (FPC20010) reflected that same division of responsibility.

If the arrangements between the co-producers were such that:

  • accounts of the FPC’s trade included expenditure that was ultimately attributable to another co-producer but
  • was incurred by the FPC

HMRC could be expected to critically test whether the expenditure should be:

  • excluded from the costs of the film because they are not incurred wholly and exclusively for the purpose of the FPC’s separate trade - FPC20230 and CTA2009/S1191(2) , and/or
  • disregarded for the purposes of determining the amount of any additional deduction or payable credit because the arrangements have been structured in such way so as to increase the FPC’s entitlement to the deduction or credit - FPC80050 and CTA2009/S1205 .