Co-productions: the Television Production Company (TPC)
S1216AE(4) Corporation Tax Act 2009
Television Tax Relief (TTR) treats qualifying co-productions differently from other programmes in one respect. The conditions which a company must meet to be treated as a Television Production Company (TPC) (TPC10110) for a co-production are relaxed.
The UK co-producer is not required to meet all the conditions listed at TPC10110 but is instead only required to make an effective creative, technical and artistic contribution to the relevant programme.
This reflects the fact that the activities that normally characterise a TPC 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 programmes made outside the terms of the UK’s official co-production agreements. In such cases, a UK co-producer can only be a TPC for the purposes of Part 15A CTA 2009 by meeting in full the requirements set out in TPC10110.