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HMRC internal manual

Television Production Company Manual

Co-productions: more than one UK co-producer

S1216AE(5) Corporation Tax Act 2009 (CTA 2009)

There cannot be more than one Television Production Company (TPC) in relation to a single programme (TPC10110). This rule holds true in the case of co-productions as it does for other programmes.

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 television programme will be treated as the TPC for the programme.

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 TPC for the purposes of Part 15A CTA 2009, even where the overseas co-producer is more actively engaged in the production of the programme as a whole.